A. Feliciano v. PA DOC
588 M.D. 2019
| Pa. Commw. Ct. | Jan 26, 2022Background
- Petitioner Anthony Feliciano, an inmate at SCI‑Mahanoy, challenged administrative punishment he received following a positive drug test, seeking a declaratory judgment for alleged procedural due process violations.
- The Commonwealth Court previously dismissed Feliciano’s original petition (Feliciano I) for lack of original jurisdiction but allowed him 30 days to file an amended petition correcting pleading defects.
- In Feliciano I the court adopted the Aref multifactor test (conditions of confinement, duration, and duration relative to similarly sentenced inmates) to determine when prison disciplinary actions implicate a protected liberty interest under Sandin.
- Feliciano filed an Amended Petition; the Department filed preliminary objections arguing lack of jurisdiction and demurrer grounds.
- The Amended Petition failed to plead facts permitting comparison of the punishment’s conditions or duration to ordinary confinement or to penalties imposed on similarly situated inmates, and did not allege an atypical or significant hardship.
- The court sustained the Department’s jurisdictional preliminary objection and dismissed the Amended Petition with prejudice.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether the court has original jurisdiction over Feliciano’s claim | Feliciano contends his procedural due process rights were violated and seeks declaratory relief | DOC argues the court lacks original jurisdiction because no protected liberty interest is implicated | Court held no jurisdiction: Amended Petition did not allege facts showing a protected liberty interest |
| Whether the administrative punishment implicated a liberty interest requiring process | Feliciano argues the punishment was sufficient to trigger Sandin protections | DOC argues the punishment was not atypical/significant and petitioner failed to plead required comparisons | Court held petitioner failed to plead conditions or duration sufficient under the Aref/Sandin framework |
| Whether the Amended Petition cured pleading defects from Feliciano I | Feliciano filed an amended pleading after being given leave to amend | DOC argued defects remained and moved to dismiss | Court held defects persisted; dismissal with prejudice affirmed |
Key Cases Cited
- Feliciano v. Pennsylvania Department of Corrections, 250 A.3d 1269 (Pa. Cmwlth. 2021) (en banc opinion adopting Aref multifactor test and outlining jurisdictional pleading requirements)
- Sandin v. Conner, 515 U.S. 472 (U.S. 1995) (liberty‑interest standard: atypical and significant hardship in relation to ordinary prison life)
- Aref v. Lynch, 833 F.3d 242 (D.C. Cir. 2016) (multifactor test: conditions of confinement, duration, and duration relative to similarly sentenced inmates)
- Hill v. Department of Corrections, 64 A.3d 1159 (Pa. Cmwlth. 2013) (liberty interest arises only from personal or property interests beyond DOC regulations)
- Key v. Pennsylvania Department of Corrections, 185 A.3d 421 (Pa. Cmwlth. 2018) (standard for ruling on preliminary objections: accept well‑pled facts)