K.J. Canfield v. PA DOC
K.J. Canfield v. PA DOC - 585 M.D. 2016
| Pa. Commw. Ct. | Aug 11, 2017Background
- Petitioner Keith J. Canfield, a DOC inmate, filed a pro se mandamus petition seeking an order compelling the Department of Corrections (DOC) to credit 581 days against a 2–10 year burglary sentence.
- On March 19, 2003 the Susquehanna County trial court sentenced Canfield to 2 to 10 years "with credit for time served as allowed by law."
- DOC’s April 30, 2003 DC-16E form showed a maximum date consistent with DOC having credited 730 days; a May 22, 2003 DC-16E then reflected credit of only 149 days (changing the maximum date).
- Attached trial-court records showed Canfield was held in jail for 149 days prior to the March 19, 2003 sentence and had been released on recognizance in 1999; Canfield did not allege any additional pre-sentence incarceration periods.
- DOC filed a preliminary objection in the nature of a demurrer, arguing Canfield had no clear legal right to mandamus relief because the sentencing order did not specify a particular number of days of credit.
- The Commonwealth Court sustained DOC’s demurrer and dismissed the petition, concluding mandamus was unavailable where the sentencing order was not specific and the DOC’s calculation matched the documented pre-sentence confinement.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether mandamus may compel DOC to restore 581 days credit | Canfield: DOC improperly reduced credit from 730 to 149 days and must reinstate the removed credit | DOC: Sentencing order only granted "credit for time served," not a specific number; DOC’s calculation matched documented pre-sentence jail time so no ministerial duty to change | Demurrer sustained; mandamus denied because no clear legal right—the sentencing order was not specific and DOC credited 149 documented days |
| Whether DOC miscalculated sentence dates contrary to sentencing order | Canfield: DOC’s change violated the trial court’s order | DOC: No error shown; Petitioner did not allege additional time served beyond 149 days | Court found no supporting averment of additional pre-sentence incarceration; no error established |
Key Cases Cited
- McCray v. Pennsylvania Department of Corrections, 872 A.2d 1127 (Pa. 2005) (mandamus available only when clear legal right and corresponding ministerial duty exist)
- Black v. Pennsylvania Department of Corrections, 889 A.2d 672 (Pa. Cmwlth. 2005) (mandamus for correcting DOC date calculations when sentencing order clearly provides credit)
- Oakman v. Pennsylvania Department of Corrections, 903 A.2d 106 (Pa. Cmwlth. 2006) (mandamus appropriate to correct DOC computation when sentence clearly grants credit)
- Saunders v. Department of Corrections, 749 A.2d 553 (Pa. Cmwlth. 2000) (mandamus unavailable where sentencing order ambiguous; trial court is proper forum for clarification)
- Hoyt v. Pennsylvania Department of Corrections, 79 A.3d 741 (Pa. Cmwlth. 2013) (same principle: no mandamus where sentencing order does not clearly provide the credit)
- Dodgson v. Pennsylvania Department of Corrections, 922 A.2d 1023 (Pa. Cmwlth. 2007) (procedural guidance on demurrer; court accepts well-pleaded facts but not legal conclusions)