Davis, T. v. Thompson, B.
1210 WDA 2017
| Pa. Super. Ct. | Nov 7, 2017Background
- Thomas Davis, an inmate at SCI-Mercer, was sentenced in 1992 to an aggregate term of 14 to 28 years.
- On June 19, 2017 Davis filed a pro se "Motion for Fraud Upon the Court," alleging the DOC miscalculated his sentence and he was held past his release date (claimed Feb 25, 2017).
- The Mercer County Court of Common Pleas denied the motion without a hearing on July 3, 2017; Davis appealed to the Superior Court.
- The trial court explained it lacked jurisdiction because the matter had been transferred to Allegheny County and because the same claim was already on appeal; the Superior Court quashed the appeal for lack of jurisdiction.
- Davis was simultaneously pursuing a challenge to the DOC’s computation in the Commonwealth Court (active at No. 632 M.D. 2016); his application to transfer that matter to the Superior Court was denied.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether DOC committed a fraud by miscomputing Davis's sentence | DOC miscalculated credit/time causing unlawful continued imprisonment | Court/ DOC argued claim challenges DOC computation and is not for common pleas; jurisdiction lies elsewhere | Court quashed appeal for lack of jurisdiction; issue belongs in Commonwealth Court or proper county court |
| Whether Mercer County trial court erred by denying motion without hearing | Davis argued fraud merits relief and hearing | Trial court said matter was transferred / on appeal so it lacked jurisdiction to decide and could not hold a hearing | Denial without hearing upheld as jurisdictional; trial court lacked authority to act |
| Proper procedural vehicle for sentence-computation claims | Davis framed claim as "fraud upon the court" to obtain relief in common pleas | Defendants/ courts: sentencing-computation claims are for Commonwealth Court or original action for mandamus, not common pleas | Court reiterated that challenges to DOC computations should be pursued in Commonwealth Court (original action/mandamus) |
| Effect of pending appeals/transfers on trial court jurisdiction | Davis sought relief despite related matters pending/ transferred | Courts argued pending appeal/transfer divests trial court of jurisdiction | Court held it lacked jurisdiction because matter had been transferred and was on appeal; appeal quashed |
Key Cases Cited
- Commonwealth v. Heredia, 97 A.3d 392 (Pa. Super. 2014) (sentence-computation errors by DOC should be pursued in Commonwealth Court)
- Commonwealth v. Wyatt, 115 A.3d 876 (Pa. Super. 2015) (actions challenging DOC computation can be examined via mandamus where statutory requirements are at issue)
- McCray v. Pennsylvania Department of Corrections, 872 A.2d 1127 (Pa. 2005) (mandamus remains viable to examine DOC computation where discretionary criteria are not contested)