L. Bullock v. PA DOC and The Medlin Training Institute
375 M.D. 2016
| Pa. Commw. Ct. | Sep 28, 2017Background
- Petitioner Lamont Bullock, an inmate at SCI‑Greene, filed an amended petition for review in the nature of a complaint in mandamus against the Pennsylvania Department of Corrections (Department) and the Medlin Training Institute (Medlin), alleging six distinct counts (mental‑health misdiagnosis/involuntary commitment; unconstitutional conditions of confinement related to cell ventilation; retaliation and denial of sex‑offender treatment; deliberate exposure to poisons/disease; denial of medical treatment/ improper co‑pays; and forced double‑celling).
- Bullock sought declaratory relief, injunctive relief (including transfer and prohibition against retaliatory transfers), medical testing and remedies, reimbursement of co‑pays, and an evidentiary hearing.
- The Department filed a preliminary objection alleging misjoinder of six unrelated causes of action and that Bullock was attempting to evade PLRA filing/three‑strikes rules. Medlin joined that objection and separately argued lack of subject‑matter and personal jurisdiction and moved to demur for legal insufficiency.
- The Court considered jurisdictional issues over Medlin, whether Bullock pleaded facts sufficient to state a mandamus claim against Medlin, and whether the six counts against the Department were improperly joined.
- The Court ruled that it had ancillary jurisdiction over Medlin because Bullock’s claims against the Department (a Commonwealth agency) lie within the Court’s original jurisdiction; however, the Court sustained Medlin’s demurrer for failure to plead facts showing a ministerial duty owed by Medlin and dismissed Bullock’s claims against Medlin without prejudice.
- The Court overruled the Department’s preliminary objection as to misjoinder, allowing Bullock’s six counts against the Department to proceed (subject to future responsive pleadings and potential amendment deadlines in the Court’s order).
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Jurisdiction over Medlin | Court has jurisdiction because claims against Medlin are related to claims against the Department | Medlin: Court lacks original/appellate jurisdiction because Medlin is a private entity, not a Commonwealth agency | Overruled — Court has ancillary jurisdiction over Medlin as related to claims against a Commonwealth agency (Department) |
| Legal sufficiency (demurrer) as to Medlin | Medlin failed to intervene and failed to train DOC; Bullock alleged he notified Medlin by letter | Medlin: No allegation it owed a ministerial/mandatory duty; no facts or authority showing duty to act | Sustained — Bullock failed to plead facts showing a legal duty by Medlin; claims against Medlin dismissed without prejudice |
| Misjoinder of multiple claims (Department) | Bullock: Permitted to plead multiple causes of action in separate counts under Pa. R.C.P. 1020(a) | Department: Six unrelated claims arise from distinct events/actors and attempt to circumvent PLRA fee/strikes rules | Overruled — Court accepted well‑pleaded allegations that the claims are related as part of an ongoing conspiracy/series of actions; counts may proceed against Department |
| Pleading standard for mandamus relief | Bullock contends mandamus is appropriate to compel corrections/remedies | Respondents: Mandamus requires showing of a ministerial duty and insufficient facts were pleaded (esp. against Medlin) | Court applied standard: legal duty must be alleged; Bullock met pleading for Department claims but failed to allege a duty owed by Medlin |
Key Cases Cited
- Bowers v. T‑Netix, 837 A.2d 608 (Pa. Cmwlth. 2003) (in ruling on preliminary objections, well‑pleaded facts and reasonable inferences are accepted as true)
- Barndt v. Pa. Dep’t of Corr., 902 A.2d 589 (Pa. Cmwlth. 2006) (on demurrer, court accepts well‑pleaded facts and reasonable inferences)
- Sweatt v. Dep’t of Corr., 769 A.2d 574 (Pa. Cmwlth. 2001) (demurrer will be sustained only where recovery is clearly precluded as a matter of law)
- Bronson v. Investigations Div., Bureau of Special Servs., Dep’t of Corr., 650 A.2d 1160 (Pa. Cmwlth. 1994) (mandamus requires allegation that defendant owes a legal duty to perform the act sought to be compelled)