C.J. Kazickas v. PBPP, 226 A.3d 109

Kazickas was paroled on January 13, 2014 (original maximum release date July 2, 2016) after convictions for drug offenses and related charges; his parole conditions warned that a CPV conviction could result in forfeiture of "street time."
In October 2015 he was arrested on DUI and later failed to report/absconded from a community corrections center; he admitted a parole violation and was recommitted as a technical parole violator (TPV) by decision recorded June 1, 2016 and was given credit for time spent on parole in good standing.
He reached the then-computed maximum on September 1, 2016 and was released from the Board’s detainer, but later pleaded guilty to separate criminal charges (Northampton County) in September–October 2016.
The Board re-lodged its warrant and on December 27, 2016 modified its prior action to recommit him as a convicted parole violator (CPV) without credit for street time, recalculating his maximum into 2019; the Board later explained the denial (unresolved drug/alcohol issues).
Kazickas administratively appealed, arguing (relying on Penjuke) the Board could not revoke street-time credit previously awarded; the Commonwealth Court affirmed the Board, holding Penjuke did not apply because the TPV and CPV conduct occurred in the same parole period.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the Board erred by denying credit for time spent on parole in good standing when it later recommitted Kazickas as a CPV after having earlier recommitted him as a TPV and granted street-time credit	Kazickas: Under Penjuke the Board cannot later revoke or "reach back" to take away street-time credit already granted; he thus completed his original sentence on Sept. 1, 2016	Board: Penjuke is inapplicable because the criminal conduct leading to CPV recommitment occurred during the same parole period as the TPV; the Board may, under §6138, deny credit and recalculate the maximum; Board provided stated reason for denial	Court affirmed: Penjuke does not control where TPV and CPV violations arise in the same parole period; Board lawfully denied street-time credit and recalculated the maximum

Penjuke v. Pa. Bd. of Prob. & Parole, 203 A.3d 401 (Pa. Cmwlth. 2019) (Board cannot "reach back" to revoke street-time credit previously granted in a prior parole period)
Young v. Pa. Bd. of Prob. & Parole, 189 A.3d 16 (Pa. Cmwlth. 2018) (once Board grants street-time credit it is applied to the original sentence and generally cannot later be revoked)
Smith v. Pa. Bd. of Prob. & Parole, 574 A.2d 558 (Pa. 1990) (Board’s recommitment terms reviewed against presumptive ranges)
Miskovitch v. Pa. Bd. of Prob. & Parole, 77 A.3d 66 (Pa. Cmwlth. 2013) (Board retains jurisdiction to recommit after maximum term if crime occurred while on parole)
Dorsey v. Pa. Bd. of Prob. & Parole, 854 A.2d 994 (Pa. Cmwlth. 2004) (definition and treatment of "street time")