HARRISBURG – The Supreme Court of Pennsylvania has reversed a win for an inmate who claimed his due process rights were violated by a number of state corrections officers during his work assignment.
James H. Williams, an inmate at SCI-Houtzdale, maintained a job assignment in the facility’s kitchen. On Dec. 30, 2016, a Department of Corrections officer performed a routine pat search on Williams prior to Williams leaving work. The officer discovered approximately 2.5 pounds of sugar concealed in Williams’ boots.
On Jan. 1, 2017, Williams filed an inmate grievance with the DOC, alleging it removed Williams from his job assignment without first affording him due process. Specifically, Williams alleged that in order for the DOC to remove Williams from his job assignment, it must first afford Williams a hearing pursuant to its own policy.
The petition further asserted that, after a unit manager conducted a support team hearing at his cell door, Williams was removed from his position of employment in the kitchen. He claimed that the DOC’s failure to follow procedures pertaining to misconduct set forth in its prison regulations, resulted in a denial of due process.
When the Commonwealth Court issued its ruling, it granted summary, declaratory and injunctive relief to Williams and directed the DOC to comply with the regulations’ procedural requirements.
Commonwealth Court Judge Robert Simpson dissented, citing Dantzler v. Wetzel, for the proposition that “an inmate who fails to identify a protected liberty or property interest cannot state a claim in the Commonwealth Court for a denial of due process by prison officials.”
“Judge Simpson is correct per this Court’s decision in Bronson v. Central Office Review Committee, which holds that the Commonwealth Court lacks original jurisdiction to entertain a prisoner’s due process challenge to the actions of prison officials, where the inmate fails to assert a constitutionally-protected liberty or property interest,” Saylor said.
“Furthermore, the cases are legion confirming that inmates have no constitutionally-protected interest in maintaining prison employment. Although the DOC has not identified the above defect, a jurisdictional impediment to judicial review may be raised by the appellate courts of their own accord.”
“In any event, appellee has never advanced a colorable defense on the merits. Indeed, he has repeatedly confirmed that he tried to leave the kitchen with two and one-half pounds of sugar secreted in his boots. The order of the Commonwealth Court is reversed, and the matter is remanded for dismissal of the petition for review,” Saylor said.
The full remainder of Saylor’s Supreme Court colleagues joined him in the opinion.
Supreme Court of Pennsylvania case 95 MAP 2019
Commonwealth Court of Pennsylvania case 82 MD 2017
From the Pennsylvania Record: Reach Courts Reporter Nicholas Malfitano at nick.malfitano@therecordinc.com