J.H. Williams v. J.E. Wetzel, 178 A.3d 920

James H. Williams (inmate) was removed from his prison job after staff found over two pounds of sugar in his boots; DOC did not issue a DC-141 misconduct report but removed him under DC-ADM 816 procedures.
DOC relied on DC-ADM 816 §1.M.7 (removal "for reasons other than misconduct or medical necessity" handled by Unit Management Team) and DC-ADM 816/801 provisions permitting refusal to assign or continue work.
Williams exhausted DOC grievances up to the Chief Grievance Officer, arguing the removal was for work-related misconduct and DOC improperly avoided the procedural protections in 37 Pa. Code § 93.10(b).
Williams sought declaratory, injunctive, and compensatory relief in this Court, alleging DOC used DC-ADM 816 to circumvent required misconduct procedures.
DOC filed preliminary objections (demurrer), arguing Williams failed to state a claim because inmates have no right to a job and DOC’s interpretation of its policy (that §1.M.7 applies when no DC-141 was issued) is controlling.
The Court treated well-pleaded facts as true and overruled the preliminary objections, concluding Williams adequately alleged DOC used DC-ADM 816 to impose sanctions tantamount to misconduct penalties without invoking §93.10(b) procedures.

Issue	Williams' Argument	DOC's Argument	Held
Whether DOC may remove an inmate from a job without triggering 37 Pa. Code §93.10(b) procedures when removal is based on conduct amounting to misconduct	Removal was based on work-related misconduct and thus DOC had to follow §93.10(b) procedures (issue DC-141 triggers those procedures)	§1.M.7 applies when no DC-141 was issued; inmates have no protected right to a job, so due process is not triggered; agency interpretation is entitled to deference	Court found Williams pled that DOC used §1.M.7 to impose misconduct-like sanctions without §93.10(b); demurrer overruled — claim survives at pleading stage

Bush v. Veach, 1 A.3d 981 (Pa. Cmwlth. 2010) (agency must follow 37 Pa. Code §93.10(b) before imposing sanctions for job removal when misconduct process is implicated)
Meier v. Maleski, 648 A.2d 595 (Pa. Cmwlth. 1994) (standard for deciding preliminary objections: accept well-pleaded facts and reasonable inferences)
Armstrong Cnty. Mem'l Hosp. v. Dep't of Pub. Welfare, 67 A.3d 160 (Pa. Cmwlth. 2013) (demurrer sustained only when petitioner fails to state a claim)
Figueroa v. Pa. Bd. of Prob. and Parole, 900 A.2d 949 (Pa. Cmwlth. 2006) (court may take judicial notice of information on official DOC website)