Buehl v. Beard
54 A.3d 412
| Pa. Commw. Ct. | 2012Background
- Buehl, an inmate at SCI-Smithfield, seeks mandamus, declaratory, and injunctive relief regarding two hours of daily physical exercise as required by 61 Pa.C.S. § 5901.
- Statute requires two hours of outdoor exercise when weather permits, otherwise two hours indoors; exceptions apply for incapacity or segregation.
- Buehl alleges the Department cancels outdoor exercise for inclement weather, fakes weather reports, and fails to provide adequate indoor exercise, restrooms, and to revoke a 600 Rule.
- Department asserts discretion over daily exercise under § 5901, contends weather determinations are not reviewable for daily decisions, and that block-out indoor exercise suffices.
- Pleadings show two hours of exercise when weather is not inclement; block-out time allows indoor exercise, and walking counts as exercise.
- Court granted the Department’s motion for judgment on the pleadings, denied Buehl’s cross-motion, and dismissed mandamus, declaratory, and injunctive relief claims.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Does § 5901 require mandamus relief to compel exercise compliance? | Buehl argues Department fails to provide two hours of exercise as required. | Department contends weather-based discretion and safety/practicality govern exercise, reviewable only for safety-and-practicality, not day-to-day. | Denied; court finds no mandamus to compel per weather discretion. |
| Is weather-based cancellation reviewable under § 5901? | Buehl claims improper use of inclement weather exception to cancel outdoor exercise. | Department's weather determinations are discretionary and not subject to mandamus review on daily decisions. | Denied; court defers to administrator’s weather discretion. |
| Does block-out indoor exercise satisfy § 5901 when outdoor exercise is canceled? | Buehl asserts indoor options do not meet required exercise. | Indoor exercise during block-out is permitted and counts toward the two hours. | Granted; indoor block-out exercise satisfies statutory requirement. |
| Does the lack of outdoor restrooms or the 600 Rule affect compliance with § 5901? | Buehl contends missing restrooms and 600 Rule impair exercise rights. | No mandatory outdoor restrooms; 600 Rule can limit outdoor time but does not violate § 5901 when total outdoor time remains two hours. | Denied; compliance remains under § 5901 as interpreted. |
| Is declaratory relief appropriate given the mandamus ruling? | Seeks declaratory judgment interpreting § 5901 as violated. | Declaratory relief would be redundant if mandamus/other relief resolves issue. | Denied; declaratory relief deemed redundant. |
| Is injunctive relief appropriate to prevent retaliation claims? | Seeks permanent injunction against retaliation for petitioning. | No actual retaliation alleged; speculative future harm insufficient for injunction. | Denied; no demonstrated likelihood of retaliation. |
Key Cases Cited
- Inmates of B-Block v. Marks, 434 A.2d 211 (Pa.Cmwlth. 1981) (review of whether exercise is safe and practical under § 5901)
- DeHart v. Horn, 694 A.2d 16 (Pa.Cmwlth. 1997) (deference to prison administration in corrections operations)
- Bell v. Wolfish, 441 U.S. 520 (U.S. 1979) (deference to executive decisions on prison administration)
- Peterkin v. Jeffes, 855 F.2d 1021 (3d Cir. 1988) (administrative discretion in prison management; security considerations)
- Robson v. Biester, 420 A.2d 9 (Pa.Cmwlth. 1980) (correctional facility operations lie largely within governmental discretion)