R. Young, Jr. v. PA DOC & Lancaster County Clerk of Courts
485 M.D. 2015
| Pa. Commw. Ct. | Dec 22, 2016Background
- Petitioner Richard Young Jr., an inmate since 1996, filed an original-jurisdiction petition asking return of $1,314.99 deducted from his inmate account from 2001–2014 to pay fines and costs.
- Deductions were taken under Act 84 to satisfy fines/costs from four criminal dockets, including CP-36-CR-0000851-1996 (Young challenges $622.07 as improperly imposed).
- Young contends one sentencing order was invalid because the trial court did not sign a written judgment and that three other sentences dated from the 1980s had expired.
- Respondents (Pennsylvania Department of Corrections and Lancaster County Clerk) filed preliminary objections arguing Young’s claim is time‑barred and fails to state a claim because fines/costs may be orally imposed and Act 84 authorizes deductions.
- Court treated the filing as a petition for review in original jurisdiction and considered whether the applicable statute of limitations barred the claim.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Timeliness — applicable SOL and accrual date | Young asserted deductions were wrongful and sought return of funds (filed 2015). | Dept./Clerk: cause accrued at first deduction (2001); two‑year statute applies so claim untimely. | Court held action governed by 2‑year SOL (42 Pa.C.S. §5524(6)); accrual at first deduction; petition untimely and dismissed. |
| Nature of action — mandamus vs. money claim | Young characterized relief as requiring return of funds/deduction reversal. | Defs: earlier precedent treated similar actions as mandamus (6‑month SOL), but recent authority rejects mandamus label here. | Court agreed action seeks recovery/nondelivery of property, not mandamus; two‑year SOL applies. |
| Requirement of written sentencing order for fines/costs | Young: absent signed written judgment, fines/costs are null and void. | Defs: fines/costs may be imposed orally; sentencing order shows costs marked for Count 5. | Court found written imposition not required and the sentencing order indicated costs; did not reach merits because of timeliness. |
| Retroactivity/authority for Act 84 deductions | Young implied Act 84 cannot apply retroactively to old sentences. | Defs cited precedent upholding retroactive application and deductions for completed supervision. | Court noted precedent (Lyons) permits retroactive, concluding merits unnecessary after dismissal on SOL grounds. |
Key Cases Cited
- Morgalo v. Gorniak, 134 A.3d 1139 (Pa. Cmwlth. 2016) (actions to recover funds deducted from inmate accounts governed by 2‑year statute and accrual at first deduction)
- Curley v. Wetzel, 82 A.3d 418 (Pa. 2013) (Supreme Court disavowed treating these claims as mandamus with a six‑month limitation; concurrence favoring two‑year SOL)
- Commonwealth v. Lyons, 830 A.2d 663 (Pa. Cmwlth. 2003) (Act 84 is procedural and may be applied retroactively; deductions may be taken for sentences after supervision ends)
- Pennsylvania Builders Ass'n v. Dep't of Labor & Indus., 4 A.3d 215 (Pa. Cmwlth. 2010) (standard of review for preliminary objections)
- Neely v. Dep't of Corrections, 838 A.2d 16 (Pa. Cmwlth. 2008) (treat well‑pleaded allegations as true on preliminary objections)