Stodghill v. Pennsylvania Department of Corrections
2016 Pa. Commw. LEXIS 501
| Pa. Commw. Ct. | 2016Background
- Petitioner David M. Stodghill, a pro se inmate at SCI‑Somerset, sought a writ of mandamus compelling the Department of Corrections (Department) to interpret 42 Pa.C.S. § 9718.1(b)(1)(ii) to mean mere participation (not completion) in the Department’s sex‑offender treatment program is sufficient for parole eligibility.
- The Department filed preliminary objections seeking dismissal under Pa. R.C.P. 1028(a)(4) for failure to state a claim, arguing the Board of Probation and Parole (Board) controls parole and that inmates have no entitlement to parole.
- The Court considered only the pleadings and noted pro se pleadings receive liberal construction. The Court found Stodghill had standing because he alleged a concrete injury (being excluded from parole consideration).
- The Department argued it has statutory discretion to define program content, scheduling, and what constitutes attendance/participation, and that the General Assembly denied a private right to enforce program requirements.
- The majority relied on statutory text giving the Department sole discretion over program content and administration and on precedent holding minimal or unsatisfactory attendance does not meet § 9718.1. The Court sustained the demurrer and dismissed the petition.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Does Stodghill have standing to seek mandamus? | He is directly affected because Department’s interpretation excluded him from parole consideration. | Department argued the pleading was generalized and did not show an individualized injury. | Court: Stodghill has a substantial, direct, immediate interest; standing established. |
| Does § 9718.1(b)(1)(ii) require only participation (not completion) to trigger parole eligibility? | Stodghill: statutory text requires only "participated," so his attendance/participation suffices. | Department: it may interpret and set program requirements; mere minimal/unsatisfactory attendance does not satisfy the statutory requirement. | Court: Defer to Department’s interpretation and discretion; participation must meet Department standards (here 120 sessions), so Stodghill’s limited participation was insufficient. |
| Can mandamus compel the Department to certify an inmate as parole‑eligible? | Stodghill: yes, if he met the statute’s participation requirement. | Department: mandamus cannot direct discretion; Department has duty to administer program and identify eligible inmates consistent with statute. | Court: Mandamus cannot force discretionary determinations; petitioner lacks a clear legal right to the relief requested, so claim fails. |
| Does § 9718.1(d) bar judicial enforcement or modification of program/mandatory parole? | Stodghill: statute’s plain language governs and allows judicial review of interpretation. | Department: § 9718.1(d) expressly denies any private right to modify program, demand parole, or bring actions concerning the program. | Court: § 9718.1(d) limits judicial relief; statute precludes conferring an enforceable right to parole or to modify program requirements. |
Key Cases Cited
- Pa. State Lodge, Fraternal Order of Police v. Dep’t of Conservation & Natural Res., 909 A.2d 413 (Pa. Cmwlth. 2006) (standard for ruling on preliminary objections; pleadings accepted as true)
- Finn v. Rendell, 990 A.2d 100 (Pa. Cmwlth. 2010) (standing requires a substantial, direct, immediate interest)
- Stodghill v. Pennsylvania Bd. of Probation & Parole, 123 A.3d 798 (Pa. Cmwlth. 2015) (participation insufficient where participation was minimal/unsatisfactory)
- Evans v. Pennsylvania Bd. of Probation & Parole, 820 A.2d 904 (Pa. Cmwlth. 2003) (statutory purpose: protect public and children; completion/meaningful participation supports rehabilitative goals)
- Wilson v. Pennsylvania Bd. of Probation & Parole, 942 A.2d 270 (Pa. Cmwlth. 2008) (denial of parole for failure to complete rehabilitative programming is valid)
- Cimaszewski v. Board of Probation & Parole, 868 A.2d 416 (Pa. 2005) (mandamus will not compel discretionary acts)