N. Williams, Jr. v. Com. of PA DOC
120 M.D. 2024
| Pa. Commw. Ct. | May 6, 2025Background
- Norman Williams, Jr., an inmate, received notices in November 2021 that the Department of Corrections (DOC) intended to deduct funds from his prison account to satisfy court-ordered financial obligations under Act 84.
- The notices explained the deductions, provided itemized amounts, informed him of his right to contest, and required a grievance to be filed within 15 working days to contest the accuracy.
- Williams timely filed a grievance; however, the DOC began making deductions before his grievance was fully resolved.
- After exhausting the DOC’s grievance process, Williams filed a pro se civil complaint, later treated as a petition for review in the Commonwealth Court’s original jurisdiction.
- Williams argued that deductions before final grievance resolution violated due process, and also argued the underlying debt was invalid because the DOC lacked a written sentencing order in response to his Right-to-Know Law (RTKL) request. Respondents filed preliminary objections (demurrer).
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Due process for Act 84 deductions prior to grievance review | Deductions before grievance resolved violate due process | DOC’s notices and process satisfied due process; policy violations not enough. | Due process satisfied; no violation. Preliminary objection sustained. |
| Liability of DOC officials for approving deductions | Officials personally involved by not stopping deductions | Only involved post hoc in grievance review, not in original deduction decision | Not personally liable. Preliminary objection sustained. |
| Validity of deductions based on lack of written sentencing | No written order produced, so amounts not owed | No law requires written/signed order; other documentation suffices | Written order not required. Preliminary objection sustained. |
| Availability of compensatory or punitive damages | Sought substantial damages for constitutional violation | No valid underlying claim; no entitlement beyond nominal damages | No entitlement. Issue moot as all claims dismissed. |
Key Cases Cited
- Bundy v. Wetzel, 184 A.3d 551 (Pa. 2018) (establishes due process requirements for Act 84 deductions from inmate accounts)
- Johnson v. Wetzel, 238 A.3d 1172 (Pa. 2020) (clarifies inmates’ due process rights before Act 84 deductions)
- Giordano v. Ridge, 737 A.2d 350 (Pa. Cmwlth. 1999) (standard for ruling on demurrers in preliminary objections)
- Allen v. Dep't of Corr., 103 A.3d 365 (Pa. Cmwlth. 2014) (documents attached to petition may override inconsistent allegations)
- Rivera v. Silbaugh, 240 A.3d 229 (Pa. Cmwlth. 2020) (grievance process participation does not create Section 1983 liability)