228 A.3d 1289
Pa.2020Background
- Stockton was originally sentenced in 2007 (two concurrent 10–20 year terms and $489 in costs per docket). Later orders in 2010 (unsigned) and 2012 (signed by a different judge) modified fees and stated two consecutive 5–10 year terms, which Stockton contends are invalid.
- DOC deducted funds from Stockton’s inmate account based on the sentencing orders; Stockton sued claiming those deductions were based on invalid/"false" orders.
- Stockton first filed an Act 84 petition in Commonwealth Court; it was dismissed as time-barred and the dismissal was affirmed by this Court.
- Stockton filed a PCRA petition (2012) raising the deductions/invalid-sentence claim; the PCRA court rejected the deductions issue as inappropriate for PCRA and advised filing in Commonwealth Court original jurisdiction; the Superior Court affirmed dismissal of the PCRA petition.
- Stockton then filed in Commonwealth Court’s original jurisdiction; the Commonwealth Court dismissed for lack of jurisdiction as a collateral attack on sentence. Justice Wecht concurred in affirmance but criticized the courts for shuttling Stockton between forums and urged application of Pa. R.A.P. 751 (transfer) except where the Smock exception clearly applies.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether Stockton’s challenge to DOC deductions may proceed as an Act 84/Commonwealth Court original-jurisdiction petition rather than under the PCRA | Stockton: deductions claim can proceed as Act 84 petition challenging DOC’s administrative deductions based on allegedly invalid orders | Respondents: Stockton’s claim effectively attacks the validity of his sentence and thus is a collateral attack that must be pursued under the PCRA | Court concluded the claim is a collateral attack on sentence and governed by PCRA principles (PCRA is the proper vehicle for sentence challenges) |
| Whether the PCRA court erred in refusing to adjudicate the deductions issue | Stockton: PCRA was an appropriate forum to obtain relief from DOC deductions | Commonwealth/PCRA court: deductions issue is not cognizable under PCRA; should be raised as petition for review in Commonwealth Court original jurisdiction | PCRA court’s characterization that the deductions issue was improperly raised in PCRA was accepted; courts repeatedly declined to adjudicate on merits |
| Whether the Commonwealth Court should have transferred Stockton’s erroneously filed petition to the proper tribunal under Pa. R.A.P. 751 instead of dismissing | Stockton (and concurrence): Rule 751 mandates transfer of matters filed in a court that lacks jurisdiction to the proper tribunal | Commonwealth Court/respondents: relied on precedent and judicially-created exceptions (e.g., Smock/Guarrasi) to dismiss rather than transfer | Justice Wecht: Rule 751’s text requires transfer, and the Commonwealth Court should have considered transfer; nevertheless, he concurs in affirmance because the Smock exception applies given Stockton’s concession that PCRA relief was futile |
| Whether the judicially created Smock exception to Rule 751 applies here | Stockton: transfer required; Smock exception inapplicable | Respondents/Commonwealth Court: dismissal appropriate where transferee cannot grant relief; precedent (Guarrasi/Smock) supports dismissal in narrow circumstances | Court affirmed dismissal, applying the narrow Smock exception; Justice Wecht concurs but warns the exception may need reexamination in future cases |
Key Cases Cited
- Commonwealth v. Descardes, 136 A.3d 493 (Pa. 2016) (PCRA governs challenges seeking relief from the judgment of sentence)
- Assouline v. Reynolds, 219 A.3d 1131 (Pa. 2019) (court refused transfer under Rule 751 in rare circumstances for judicial-economy reasons)
- Smock v. Commonwealth, 436 A.2d 615 (Pa. 1981) (plurality) (court may refuse transfer where transferee could grant no relief)
- Meehan v. Cheltenham Township, 189 A.2d 593 (Pa. 1963) (court decided merits despite jurisdictional defect to terminate litigation)
- Guarrasi v. Scott, 25 A.3d 394 (Pa. Cmwlth. 2011) (Commonwealth Court precedent addressing overlap of PCRA and original-jurisdiction petitions)
- Stockton v. Dougherty, 88 A.3d 968 (Pa. 2014) (per curiam) (prior appellate resolution of Stockton’s related petition)