L. Brown v. York County Prison
L. Brown v. York County Prison - 590 C.D. 2016
| Pa. Commw. Ct. | Apr 5, 2017Background
- Inmate Lamar Brown pled guilty to three robbery counts in 2003 and later filed post-conviction claims that his plea was not knowing because medication affected him; his post-conviction petition was denied in 2011.
- In 2013 Brown sued York County Prison, its medical department, and several private medical providers seeking damages and his medical records; the trial court dismissed the complaint on preliminary objections.
- This Court in a prior decision reinstated Brown’s claims against some defendants but dismissed Corizon/Prison Health Services; the case returned to the trial court for further proceedings.
- On remand the trial court again sustained preliminary objections and dismissed Brown’s claims by orders dated March 3 and March 23, 2016; Brown, proceeding pro se and incarcerated, appealed and was ordered to file a Pa.R.A.P. 1925(b) statement.
- Brown’s 1925(b) statement bears a signature date of June 19, 2016 (before the June 21 deadline) but was not stamp-filed by the prothonotary until June 27; the trial court deemed the statement untimely and found waiver.
- The Commonwealth Court found a factual dispute whether the prisoner mailbox rule made Brown’s 1925(b) statement timely and remanded for an evidentiary hearing; if timely, the trial court must issue a new 1925(a) opinion addressing Brown’s sole issue (denial of leave to amend).
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Was Brown’s Pa.R.A.P. 1925(b) statement timely under the prisoner mailbox rule? | Brown contends the signature date (June 19, 2016) shows he delivered it to prison officials before the June 21 deadline. | Defendants rely on the prothonotary’s June 27 stamp to show it was late and therefore waived. | Remanded: factual dispute exists; trial court must hold evidentiary hearing to decide timeliness. |
| Did the trial court properly deem Brown’s issues waived for untimely filing? | Brown argues he did file timely under the mailbox rule and thus did not waive issues. | Trial court held filing untimely and found waiver. | Vacated the trial court’s March 3, 2016 order pending resolution of timeliness; waiver not finally resolved. |
| If timely, must the trial court address Brown’s motion to amend? | Brown sought leave to add the Warden based on a contract suggesting access to records; he asked the court to rule on his motion to amend. | Defendants treated preliminary objections as dispositive and sought dismissal. | If trial court finds the 1925(b) timely, it must issue a new 1925(a) opinion addressing whether leave to amend should have been granted. |
| Should the appellate court retain jurisdiction and remand? | Brown sought appellate review of the dismissal orders. | Defendants argued dismissal was final and proper. | Appellate court retained jurisdiction and remanded for the limited evidentiary hearing on timeliness. |
Key Cases Cited
- Commonwealth v. Butler, 812 A.2d 631 (Pa. 2002) (untimely Rule 1925(b) statement results in waiver absent extraordinary circumstances)
- In re Clinton Cnty. Tax Claims, 109 A.3d 331 (Pa. Cmwlth. 2015) (timely compliance with Rule 1925(b) is required; untimely filing generally waives issues)
- Kittrell v. Watson, 88 A.3d 1091 (Pa. Cmwlth. 2014) (prisoner mailbox rule applies to pro se inmate filings)
- Smith v. Pennsylvania Bd. of Probation & Parole, 683 A.2d 278 (Pa. 1996) (rationale for prisoner mailbox rule given prisoners’ inability to monitor filing processes)
- Commonwealth v. Jones, 700 A.2d 423 (Pa. 1997) (when timeliness facts are disputed, remand for evidentiary hearing may be warranted)
- Commonwealth v. Castillo, 888 A.2d 775 (Pa. 2005) (cases applying waiver principle to untimely Rule 1925(b) statements)