Hill v. Department of Corrections
2013 Pa. Commw. LEXIS 103
| Pa. Commw. Ct. | 2013Background
- Hill, an inmate at SCI-Houtzdale, was found guilty of arson and other misconduct after a disciplinary hearing.
- The misconduct hearing sanctioned Hill and directed damages against his inmate account for destroyed property (two sheets, one blanket, one mattress).
- An assessment hearing was conducted to determine the amount deducted from Hill’s inmate account, with invoices from PIBH and Correctional Industries admitted as evidence.
- Hill challenged the assessment on multiple grounds, including lack of authority to deduct from a spouse’s account, due process, and hearsay evidence.
- Donna Hill, Hill’s wife, sought standing to challenge the assessment, but the court granted the DOC’s motion to quash and dismissed her as a petitioner.
- The court ultimately affirmed the assessment order and granted the DOC’s Motion to Quash.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Standing of Donna Hill to appeal | Donna Hill has a proprietary interest in the jointly held account | Hill lacks standing; the account is inmate personal, not joint | Donna Hill lacks standing; dismissed as petitioner |
| Due process at Holloway hearing | Insufficient opportunity to inspect items and cross-examine witnesses; inflated damages | Hill had notice, opportunity to cross-examine Manager; record supports findings | Due process satisfied; findings supported by record and testimony |
| Admissibility of invoices (hearsay) | Invoices are unauthenticated hearsay | Invoices are business records authenticated by custodian; corroborated by witness | Invoices admitted as business records; substantial evidence supports assessment |
Key Cases Cited
- Bronson v. Central Office Review Comm., 554 Pa. 317 (1998) (inmate misconduct generally not reviewable, but Holloway exception applies to assessments)
- Holloway v. Lehman, 671 A.2d 1179 (Pa.Cmwlth.1996) (procedural due-process requirements for inmate assessments)
- Moss v. Dep’t of Corr., 838 A.2d 32 (Pa.Cmwlth.2003) (limitations on appeal; Holloway framework; review of assessment damages only)
- Speight v. Department of Corrections, 989 A.2d 77 (Pa.Cmwlth.2010) (unobjected-to medical bills require corroboration; business records exception applies here)