185 A.3d 979
Pa.2018Background
- Inmate Robert Benchoff disputed DOC deductions from his inmate account for medical copays, alleging he was charged for four prescriptions but received only two.
- Benchoff exhausted DOC's internal grievance process (37 Pa. Code § 93.9) and sought reimbursement and an Administrative Agency Law hearing; DOC maintained the charges and denied relief through appeals.
- Benchoff filed a pro se petition for review in the Commonwealth Court seeking a writ of mandamus and claiming the grievance process denied due process because it failed to provide statutorily required notice and a hearing (2 Pa.C.S. § 504).
- DOC moved to dismiss under Bronson, arguing the Commonwealth Court lacked original jurisdiction because Benchoff's claim involved rights lawfully limited by DOC regulations (medical copay rules) and did not assert a constitutional right uncurtailed by DOC.
- The Commonwealth Court sustained DOC's preliminary objections and dismissed Benchoff's petition for lack of original jurisdiction; the Supreme Court affirmed per curiam.
- Justice Wecht concurred but wrote separately to criticize Bronson as potentially inconsistent with statutory jurisdiction and constitutional access-to-courts principles, urging reconsideration of Bronson in a suitable case.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether Commonwealth Court has original jurisdiction over Benchoff's mandamus petition challenging DOC's medical-copay deductions | Benchoff: his property interest in inmate account was deprived without due process; DOC grievance process failed to provide an Administrative Agency Law hearing | DOC: under Bronson, Commonwealth Court lacks original jurisdiction unless inmate asserts a constitutional right not limited by DOC; medical copays are regulated so claim is not reviewable | Court: Affirmed dismissal; under Bronson, original jurisdiction did not lie because DOC regulations lawfully limited the right at issue |
| Nature of the right at issue | Benchoff: claim is deprivation of property (inmate account funds) for medications never received | DOC: framed claim as entitlement to free medical services, which is not a constitutional right | Held: Court agreed Bronson controls; but Wecht noted the proper characterization is a property interest deprivation, not a free-service claim |
| Whether Bronson is consistent with statute and access-to-courts | Benchoff: (implicit) statutory/constitutional remedies should be available despite DOC rules | DOC: relies on Bronson precedent limiting review | Held: Wecht: Bronson may be inconsistent with 42 Pa.C.S. § 761 and the DOC regulation preserving court access (37 Pa.Code § 93.9(b)); recommended reconsideration in a suitable case |
| Whether the DOC grievance regulation preserves meaningful judicial review | Benchoff: § 93.9(b) preserves pursuit of state/federal remedies | DOC: argued grievance process and directives limit rights and foreclose Commonwealth Court review under Bronson | Held: Wecht: regulation expressly preserves court access, but Bronson gives no guidance for how inmates may obtain review; practical barriers remain and Bronson's reasoning is thin |
Key Cases Cited
- Bronson v. Central Office Review Committee, 721 A.2d 357 (Pa. 1998) (establishes rule limiting Commonwealth Court original jurisdiction over inmate grievance decisions unless right is not limited by DOC regulations)
- Buck v. Beard, 879 A.2d 157 (Pa. 2005) (recognizes inmates' constitutional property interest in inmate accounts and entitlement to due process for money deprivation)
- Brown v. Wetzel, 177 A.3d 200 (Pa. 2018) (Wecht, J., dissenting) (criticizes Bronson and underscores § 93.9(b)'s preservation of access to courts)
- McCray v. Dep't of Corr., 872 A.2d 1127 (Pa. 2005) (cites DOC regulation expressly permitting inmates to pursue state and federal remedies)
- Beneficial Consumer Disc. Co. v. Vukman, 77 A.3d 547 (Pa. 2013) (statutory interpretation principle: do not construe statutes to decrease court jurisdiction absent clear legislative mandate)
- Armstrong Sch. Dist. v. Armstrong Educ. Ass'n, 595 A.2d 1139 (Pa. 1991) (statutory construction canon cited regarding judicial jurisdiction)
- Commonwealth v. Giulian, 141 A.3d 1262 (Pa. 2016) (court should not add requirements not included by General Assembly)
- Robson v. Biester, 420 A.2d 9 (Pa. Cmwlth. 1980) (discusses reduced procedural protections in prison disciplinary contexts)
- Wolff v. McDonnell, 418 U.S. 539 (U.S. 1974) (recognized limited due process rights in prison disciplinary proceedings)
- Hudson v. Palmer, 468 U.S. 517 (U.S. 1984) (prisoners' rights may be limited if inconsistent with incarceration objectives)
- Lawson v. Dep't of Corr., 539 A.2d 69 (Pa. Cmwlth. 1988) (cited in Bronson for limiting review of inmate claims)