L. Saunders v. PA DOC
L. Saunders v. PA DOC - 1221 C.D. 2016
Pa. Commw. Ct.Aug 10, 2017Background
- Petitioner Lamont Saunders, an inmate at SCI‑Dallas, filed a Right‑to‑Know Law (RTKL) request with the Pennsylvania Department of Corrections seeking a copy of his written judgment of sentence (including judge’s signature and statutory authority for life without parole) for docket CP‑51‑CR‑0700051‑2003.
- The Department’s Open Records Officer denied the request, stating the requested records do not exist in the Department’s possession.
- The Department submitted an attestation by the Corrections Records Supervisor that a reasonable search found no responsive records in custody, possession, or control of the institution.
- The Office of Open Records (OOR) issued a Final Determination upholding the Department, finding no responsive records exist.
- Saunders appealed to this Court but did not challenge the OOR’s determination; instead he sought to use the RTKL appeal to challenge the legality of his confinement and requested remand to the Court of Common Pleas to pursue habeas corpus relief.
- The Commonwealth Court treated the filing as an improper collateral attack via the RTKL process and affirmed the OOR’s Final Determination.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether the RTKL appeal can be used to challenge the legality of petitioner’s confinement | Saunders argued absence of a written judgment in DOC custody renders his incarceration unconstitutional and sought remand to pursue habeas corpus | DOC argued the RTKL governs access to records and that no responsive records exist in its possession; RTKL is not a vehicle to attack confinement | Court held RTKL appeal is not the proper vehicle to collaterally attack a criminal sentence; affirmed OOR |
| Whether the Department met its burden to show no responsive records exist | Saunders implied records must exist and their absence shows illegality | DOC submitted a sworn attestation that a reasonable search found no responsive records | Court accepted the attestation and OOR’s finding that no responsive records exist |
| Proper remedy for challenging the legality of a sentence | Saunders sought remand to file habeas corpus via RTKL appeal | DOC and precedent pointed to separate statutory remedies for sentence challenges | Court explained Post Conviction Relief Act (and habeas/collateral review) are proper avenues, not RTKL |
| Whether this Court can provide relief outside RTKL on review of OOR determination | Saunders sought substantive relief beyond reviewing OOR's decision | DOC maintained appeal limited to RTKL issues; collateral relief not available in this forum | Court refused to provide collateral-relief remedy and affirmed OOR |
Key Cases Cited
- Foster v. Pennsylvania Department of Corrections, 159 A.3d 1020 (Pa. Cmwlth. 2017) (cannot use RTKL to collaterally attack sentence)
- Moore v. Office of Open Records, 992 A.2d 907 (Pa. Cmwlth. 2010) (RTKL appeal is not the proper forum to challenge continued incarceration)
- Commonwealth v. Descardes, 136 A.3d 493 (Pa. 2016) (Post Conviction Relief Act is the exclusive state remedy for prisoners challenging allegedly illegal sentences)
- Bowling v. Office of Open Records, 75 A.3d 453 (Pa. 2013) (standard of review on RTKL appeals to Commonwealth Court is de novo with plenary scope)