J.H. Williams v. J.E. Wetzel (Secretary of Corrections), 222 A.3d 49

James H. Williams, an inmate at SCI‑Houtzdale, worked in the prison kitchen; a December 30, 2016 pat search found ~2.5 lbs of sugar in his boots. DOC did not issue a DC‑141 misconduct report.
On January 4, 2017 a Unit Management Team removed Williams from his job under DC‑ADM 816 §1.M.7 ("removal for reasons other than misconduct"). Williams grieved, asserting DOC bypassed the procedural protections in DC‑ADM 801 and 37 Pa. Code §93.10(b).
DOC denied the grievance and appeals, maintaining §1.M.7 permitted removal without the §93.10(b) procedures and that inmates have no right to a specific work assignment.
Williams sought judicial relief; the Commonwealth Court previously overruled DOC’s preliminary objections and proceeded on summary relief.
The majority held DC‑ADM 816’s phrase "other than misconduct" means acts that are not misconduct (not merely the absence of a DC‑141), that DOC may not use §1.M.7 to evade §93.10(b) when the removal is for conduct amounting to misconduct, and ordered DOC to provide the §93.10(b) procedures to Williams.
Judge Simpson dissented, arguing (inter alia) that prison policies do not create enforceable liberty interests (citing Sandin), that policy disclaimers negate contractual rights, and that earlier en banc authority undermines Bush v. Veach.

Issue	Plaintiff's Argument	Defendant's Argument	Held
May DOC remove an inmate from a job for conduct amounting to misconduct without following 37 Pa. Code §93.10(b) procedures when no DC‑141 was issued?	Williams: No — DOC used DC‑ADM 816 to circumvent mandatory §93.10(b) protections for misconduct‑based job removal.	DOC: Yes — §1.M.7 allows removal for "reasons other than misconduct," which DOC reads as "other than issuance of a DC‑141," so §93.10(b) need not apply.	Court: "Misconduct" refers to the act, not issuance of a DC‑141; DOC may not use §1.M.7 to avoid §93.10(b). DOC must provide notice, hearing/ informal resolution, assistance, written reasoning, and appeal rights.
Is the court required to defer to DOC’s interpretation of its administrative directive (DC‑ADM 816)?	Williams: DOC’s interpretation is unreasonable and conflicts with DC‑ADM 801 and §93.10.	DOC: Agency deference is appropriate to its interpretation of its own directives.	Court: No deference is needed because the phrase is unambiguous; even if deference applied, DOC’s interpretation would be unreasonable and contrary to DC‑ADM 801 and §93.10.

Bush v. Veach, 1 A.3d 981 (Pa. Cmwlth. 2010) (agency must follow §93.10 procedures before imposing job‑removal sanctions for misconduct)
Martin v. Occupational Safety & Health Review Comm’n, 499 U.S. 144 (U.S. 1991) (deference to agency interpretation when regulatory language is ambiguous and interpretation is reasonable)
Turchi v. Philadelphia Bd. of License & Inspection Review, 20 A.3d 586 (Pa. Cmwlth. 2011) (discussion of deference to local/quasi‑judicial agency interpretations)
Popowsky v. Pa. Pub. Util. Comm’n, 853 A.2d 1097 (Pa. Cmwlth. 2004) (agencies must adhere to their own duly promulgated regulations)
Sandin v. Conner, 515 U.S. 472 (U.S. 1995) (prison regulations do not automatically create a constitutionally protected liberty interest)
Teledyne Columbia‑Summerill Carnegie v. Unemployment Comp. Bd. of Review, 634 A.2d 665 (Pa. Cmwlth. 1993) (a duly promulgated regulation has the force of law and must be applied)