Montanez v. Secretary Pennsylvania Department of Corrections
773 F.3d 472
| 3rd Cir. | 2014Background
- Two inmates challenge Pennsylvania DOC’s automatic deduction of 20% from inmate accounts to satisfy court-ordered restitution, fines, and costs under Act 84 and DOC Policy DCADM005.
- Policy authorizes deductions when a sentencing order includes monetary obligations and the inmate balance exceeds $10; deductions are automatic without a pre-deprivation hearing.
- Hale (sentenced 1/6/2004) and Montañez (sentenced 1/7/2000) allege lack of notice and opportunity to be heard before deductions began.
- Disputes over Hale’s notice regarding the DOC Policy and the total amount of obligations; Hale had no pre-deduction hearing, though he received some handbook material.
- Montañez asserted he never received total obligation details or the 300B form and did not have pre-deduction notice; deductions began in April 2000 and continued until 2010.
- District Court granted summary judgment against the plaintiffs on Montañez’s statute of limitations and Hale’s damages, but the court found Hale’s due process claim unpersuasive and denied injunctive relief; the Third Circuit reverses in part and remands for Hale’s injunctive relief consideration.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Accrual of Montañez’s §1983 claim | Montañez argues accrual occurred later, upon grievance denial. | Defendants argue accrual when the injury occurred, i.e., first deduction in 2000. | Montañez’s claim accrued in 2000; time-barred. |
| Pre-deprivation process requirement | Hale contends notice and a pre-deduction hearing were required before first deductions. | Defendants contend post-deprivation remedies suffice and pre-deprivation not required. | Pre-deprivation notice/hearing required; district court erred. |
| Hale’s pre-deprivation due process sufficiency | Hale asserts he was not informed of the Policy/amount before deductions and had no pre-deduction opportunity to object. | Defendants rely on sentencing and post-deprivation processes and Buck v. Beard to limit pre-hearing. | Genuine disputes of material fact exist; summary judgment reversed as to Hale's due process claim; injunctive relief remanded. |
| Qualified immunity for damages | Hale argues defendants violated clearly established rights; immunity should not shield damages. | At the time, confusion in case law supported qualified immunity. | District Court affirmed on damages; court reserves injunctive relief; qualified immunity affirmed for damages. |
Key Cases Cited
- Higgins v. Beyer, 293 F.3d 683 (3d Cir.2002) (predeprivation notice may be required to prevent deprivation of funds from inmate accounts)
- Tillman v. Lebanon County Corr. Facility, 221 F.3d 410 (3d Cir.2000) (predeprivation not required for routine fixed-fee deductions; but some predeprivation notice may be needed)
- Buck v. Beard, 879 A.2d 157 (Pa.2005) (state law on ability to pay; informs due process but not dispositive for predeprivation notice)
- Reynolds v. Wagner, 128 F.3d 166 (3d Cir.1997) (inmate funds; focuses on interest in funds and necessity of access to care; predeprivationNotice considerations)
- Kach v. Hose, 589 F.3d 626 (3d Cir.2009) (accrual and tolling principles for § 1983 claims)