Com. v. S. Steinman
134 C.D. 2016
Pa. Commw. Ct.Oct 18, 2016Background
- Appellant Seth Steinman, serving a state prison sentence for rape (convicted 2005), petitioned in Feb. 2015 to expunge a 1982 Philadelphia ordinance arrest he says was dismissed in 1984.
- The Philadelphia Court of Common Pleas denied the petition in April 2015; Steinman appealed.
- Trial court relied on Commonwealth v. Wallace, applying Mathews v. Eldridge balancing, holding inmates have no immediate due-process right to petition for expungement while incarcerated.
- Court emphasized governmental interests: maintaining complete records for in-prison discipline and parole decisions, and fiscal/security burdens of transporting inmates to court.
- Steinman argued Wallace is distinguishable; he asserted denial risks continued reliance on allegedly inaccurate records by the Parole Board and raised double jeopardy concerns.
- Commonwealth Court affirmed, finding no abuse of discretion and that due process does not guarantee an incarcerated person an immediate right to petition for expungement; double jeopardy principles were inapplicable to parole/administrative decisions.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether an incarcerated person has a due-process right to petition for expungement while imprisoned | Steinman: Wallace is distinguishable; he needs expungement now to prevent parole or prison penalties based on erroneous records | Commonwealth/Trial court: Wallace controls; Mathews balancing disfavors a right to immediate expungement due to low risk of harm and strong governmental interests | Denied — No immediate due-process right while incarcerated (affirmed) |
| Whether denial of expungement implicates Double Jeopardy | Steinman: Parole Board reliance on unexpunged records could amount to additional punishment or repeated jeopardy | Commonwealth: Parole decisions are administrative, not criminal—double jeopardy protections do not apply | Denied — Double jeopardy inapplicable to parole revocation/administrative use of records |
| Whether trial court abused its discretion in denying expungement | Steinman: Court failed to properly distinguish precedent and consider record accuracy harms | Trial court: Applied controlling precedent (Wallace/Wexler) and legitimate penological/administrative concerns | Denied — No abuse of discretion; affirmance appropriate |
| Relevance of accuracy of non-conviction records to parole/rehabilitation | Steinman: Accurate record is critical; expungement necessary to avoid future penalties | Commonwealth: Accuracy must be balanced against institutional needs; inmate may petition after release | Resolved for Commonwealth — institutional/parole interests prevail while incarcerated |
Key Cases Cited
- Commonwealth v. Wallace, 97 A.3d 310 (Pa. 2014) (held incarcerated persons lack a due-process right to immediate expungement; applied Mathews balancing)
- Mathews v. Eldridge, 424 U.S. 319 (U.S. 1976) (three-factor due-process balancing test)
- Rivenbark v. Pennsylvania Board of Probation and Parole, 501 A.2d 1110 (Pa. 1985) (parole revocation is administrative; double jeopardy protections generally inapplicable)
- Commonwealth v. Wexler, 431 A.2d 877 (Pa. 1981) (expungement is discretionary; factors to balance individual harm and Commonwealth interest)
- Carlacci v. Mazaleski, 798 A.2d 186 (Pa. 2002) (expungement petition tied to due-process interests)
- Morrissey v. Brewer, 408 U.S. 471 (U.S. 1972) (parole revocation is not a criminal prosecution)