L.W. Thomas v. PA DOC
256 M.D. 2023
Pa. Commw. Ct.Apr 14, 2025Background
- Landon W. Thomas, an inmate in the Pennsylvania prison system, filed a Petition for Review alleging First Amendment retaliation by Department of Corrections officials after filing two administrative complaints.
- The first complaint alleged a correctional officer sexually assaulted Thomas and that the subsequent misconduct charges and consequences were retaliatory.
- The second complaint involved allegations of staff complicity in allowing white supremacist inmates to control the prison’s Veteran’s Service Unit (VSU), followed by Thomas's grievance and his later transfer to another facility.
- Thomas sought both injunctive relief (restoration to the VSU) and monetary damages (for moving costs and back pay).
- The Department of Corrections responded with preliminary objections, contesting the court’s jurisdiction and the legal sufficiency of the claims.
- The Commonwealth Court, sua sponte, held it lacked jurisdiction because the main relief sought was monetary damages, and transferred the case to the Court of Common Pleas of Clearfield County for further proceedings.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Court jurisdiction over §1983 damages | Court can hear his First Amendment/damages claims | Claims for money damages must be in Common Pleas | Lacked jurisdiction; transfer ordered |
| Retaliation for administrative complaints | Respondents retaliated due to his complaints | (Not reached; addressed via preliminary objections) | Not adjudicated; jurisdictional basis only |
| Request for injunctive relief | Seeks transfer back to VSU or similar facility | (Not reached; addressed via preliminary objections) | Moot (already transferred to another VSU) |
| Handling of preliminary objections | Preliminary objections should not bar action | Raised jurisdictional and merits objections | Not reached; Common Pleas to address |
Key Cases Cited
- Balshy v. Rank, 490 A.2d 415 (Pa. 1985) (defining trespass actions and their jurisdictional implications)
- Stackhouse v. Com., 832 A.2d 1004 (Pa. 2003) (monetary damage claims against Commonwealth must be heard in Court of Common Pleas)
- Fawber v. Cohen, 532 A.2d 429 (Pa. 1987) (injunctive/declaratory relief may fall within Commonwealth Court jurisdiction)
- Hill v. Pa. Dep’t of Env’t Prot., 679 A.2d 773 (Pa. 1996) (claims for money damages under §1983 outside Commonwealth Court’s original jurisdiction)