A. Jacobs v. Superintendent M. Clark (SCI Albion) Secretary of Corrections J.E. Wetzel
38 C.D. 2017
| Pa. Commw. Ct. | Oct 23, 2017Background
- Andre Jacobs, a state inmate, filed a petition for writ of habeas corpus challenging (1) the calculation/expiration of his state sentence and refusal to transfer him to federal custody, and (2) over 16 years of punitive solitary confinement and denial of mental-health treatment.
- Jacobs filed a petition to proceed in forma pauperis in Erie County; the trial court dismissed that petition for lack of subject-matter jurisdiction, reasoning Commonwealth Court has exclusive jurisdiction over suits against Commonwealth officers.
- Jacobs argued venue was proper in Erie County under Pa. R. Crim. P. 108(B) (habeas challenging conditions is filed where petitioner is confined) and, alternatively, that the trial court should have transferred the matter under 42 Pa. C.S. §5103(a).
- The trial court denied reconsideration as moot, asserted it had not reviewed the habeas petition’s merits, and repeated that jurisdiction lay with Commonwealth Court.
- Commonwealth Court reviewed denial of in forma pauperis status and held the trial court erred: Section 761(a)(1)(i) removes Commonwealth Court’s original jurisdiction over writs of habeas corpus challenging confinement conditions, and Rule 108(B) directs such petitions to the common pleas court where the prisoner is confined.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether the trial court properly dismissed Jacobs’ in forma pauperis petition for lack of subject-matter jurisdiction | Jacobs: habeas petition challenges conditions of confinement in Erie County; Rule 108(B) vests venue in the court of common pleas where confined; trial court should have retained or transferred, not dismissed | Prison Officials: claims against Commonwealth officers seeking equitable relief fall in Commonwealth Court under 42 Pa.C.S. §761(a)(1) and Stackhouse | Court: Dismissal for lack of jurisdiction was erroneous; Commonwealth Court lacks original jurisdiction over non-ancillary writs of habeas corpus under §761(a)(1)(i); remand for trial court to review habeas petition and reconsider in forma pauperis request |
| Whether the identity of Commonwealth officer defendants alone determines subject-matter jurisdiction | Jacobs: identity of defendants does not control; the nature of the relief (habeas challenging conditions) determines forum | Prison Officials: presence of Commonwealth defendants places matter in Commonwealth Court | Court: Identity alone is not determinative; statutory exception for habeas in §761(a)(1)(i) and Rule 108 control venue and jurisdiction |
Key Cases Cited
- Stackhouse v. Pennsylvania State Police, 832 A.2d 1004 (Pa. 2003) (discusses Commonwealth Court original jurisdiction over actions involving Commonwealth officers and when trial court is proper forum)
- Bronson v. Domovich, 628 A.2d 1177 (Pa. Super. 1993) (habeas challenging conditions of confinement properly filed in judicial district where petitioner is confined)
- Neitzke v. Williams, 490 U.S. 319 (U.S. 1989) (defines frivolous suits lacking an arguable basis in law or fact)
- Grant v. Blaine, 868 A.2d 400 (Pa. 2005) (denial of in forma pauperis is final and appealable because it effectively bars access to the courts)