250 A.3d 1269
Pa. Commw. Ct.2021Background
- Feliciano, an inmate at SCI‑Mahanoy, tested positive for buprenorphine; he was placed in restricted housing on August 6, 2019.
- The Department issued a misconduct report; an earlier misconduct was dismissed without prejudice and a second report led to an August 26, 2019 disciplinary hearing.
- At the August 26 hearing Feliciano pled not guilty but was found guilty and punished with 30 days disciplinary custody (retroactive to August 6).
- Feliciano alleges he was not provided misconduct paperwork or urinalysis results before the hearing, impairing his ability to prepare a defense; his internal grievances were rejected for nonconformance.
- He filed a Petition for Review in Commonwealth Court seeking a declaration that the Department violated his procedural due process rights.
- The Department filed preliminary objections arguing lack of jurisdiction and that no protected liberty interest was implicated; the Court dismissed without prejudice, sustaining the Department’s jurisdictional objection and permitting amendment within 30 days.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether Commonwealth Court has appellate jurisdiction over prison misconduct adjudications | Feliciano sought review of the misconduct outcome | Dept: inmate misconducts are internal prison matters not subject to appellate review | Court: No appellate jurisdiction; inmate misconducts are internal management matters and not adjudications for appellate review |
| Whether Court has original jurisdiction to hear alleged due process violation | Feliciano contends withholding evidence denied procedural due process | Dept: Petitioner fails to identify a protected liberty interest, so no due process triggered | Court: Original jurisdiction lacking because Petitioner did not plead facts showing an "atypical and significant" hardship implicating a liberty interest |
| Whether failure to receive misconduct paperwork/urinalysis before hearing states a Wolff claim | Feliciano alleges lack of notice and inability to present evidence/witnesses as required by Wolff | Dept: no protected liberty interest, so Wolff protections not required here | Court: Facts, as pled, suggest potential Wolff defects but Petitioner failed to plead that the confinement was atypical/significant under Sandin; therefore claim insufficient as pled |
| Whether dismissal is with prejudice and whether amendment is allowed | N/A — Petitioner seeks relief on merits | Dept sought dismissal via preliminary objections | Court: Petition dismissed without prejudice; Petitioner granted 30 days to file an amended petition with factual detail required by Sandin/Aref test |
Key Cases Cited
- Wolff v. McDonnell, 418 U.S. 539 (1974) (articulates procedural due process components for prison disciplinary hearings)
- Sandin v. Conner, 515 U.S. 472 (1995) (due process protections arise only when confinement imposes an "atypical and significant" hardship)
- Aref v. Lynch, 833 F.3d 242 (D.C. Cir. 2016) (adopted as guiding test: compare conditions, duration, and relative duration to determine atypicality)
- Hill v. Dep’t of Corr., 64 A.3d 1159 (Pa. Cmwlth. 2013) (inmate misconducts are generally internal prison management not subject to appellate review)
- Dantzler v. Wetzel, 218 A.3d 519 (Pa. Cmwlth. 2019) (placement in disciplinary custody for 30 days did not implicate protected liberty interest)
- Sanders v. Wetzel, 223 A.3d 735 (Pa. Cmwlth. 2019) (placement in segregated confinement does not per se create a liberty interest triggering Wolff protections)
- Chem v. Horn, 725 A.2d 226 (Pa. Cmwlth. 1999) (refused to find protected interest in remaining in general population after drug‑test related disciplinary action)
- Brown v. Blaine, 833 A.2d 1166 (Pa. Cmwlth. 2003) (dismissal where petitioner failed to plead conditions appreciably different from similarly situated inmates)