T.E. Huyett v. PSP
T.E. Huyett v. PSP - 516 M.D. 2015
| Pa. Commw. Ct. | Aug 17, 2017Background
- Petitioner Thomas Huyett pleaded guilty in 2005 to three third‑degree felonies (including possession of child pornography and unlawful contact with a minor) pursuant to an open plea; sentencing court’s Notification stated a 10‑year registration requirement.
- At the time of plea/sentencing Megan’s Law II/III required 10‑year registration; SORNA (2012) later imposed lifetime registration for certain offenders.
- PSP notified Huyett after SORNA’s enactment that he was subject to lifetime registration; he asked PSP to remove his name from the public website and sought enforcement of his alleged 10‑year plea term.
- Huyett filed a petition in mandamus in this Court challenging retroactive application of SORNA and seeking enforcement of his alleged plea bargain term; he pressed due process (ex post facto), equal protection, and breach‑of‑contract claims.
- PSP filed preliminary objections asserting the petition was time‑barred, mandamus was unavailable, and that each substantive claim failed as a matter of law (including that PSP was not a proper party for the contract claim).
- The Court overruled PSP’s statute‑of‑limitations and mandamus objections and overruled the demurrer to the due process claim (post‑Muniz), but sustained demurrers to the equal protection and breach‑of‑contract claims (dismissing those two with prejudice).
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Timeliness / availability of mandamus | Huyett sought mandamus to enforce plea term and termination of registration; claimed timely | PSP argued petition barred by statute of limitations and mandamus unavailable against PSP | Overruled — court followed Taylor precedent; mandamus may lie and petition not time‑barred |
| Due process / ex post facto (retroactivity of SORNA) | Retroactive application of SORNA’s lifetime registration impairs plea obligations and violates due process/ex post facto | PSP argued SORNA is non‑punitive so retroactive application is lawful | Overruled PSP demurrer — after Muniz (SORNA held punitive for ex post facto), claim survives demurrer |
| Equal protection | Huyett claimed unequal treatment between offenders with enforceable plea bargains and others | PSP argued no suspect class, no differential treatment by SORNA; rational basis applies | Sustained — Petitioner failed to plead a cognizable equal protection claim; dismissed with prejudice |
| Breach of plea agreement / contract | Huyett alleged the 10‑year registration term was part of plea bargain and PSP must enforce it | PSP argued it is not a party to plea agreements; disputes over plea terms belong against the Commonwealth/sentencing court; PSP’s role is ministerial | Sustained — breach claim against PSP dismissed with prejudice; PSP not proper party and Notification did not prove plea term binding PSP |
Key Cases Cited
- Commonwealth v. Muniz, 164 A.3d 1189 (Pa. 2017) (SORNA’s registration provisions are punitive for ex post facto purposes)
- Dougherty v. Pennsylvania State Police, 138 A.3d 152 (Pa. Cmwlth. 2016) (PSP’s role under SORNA is ministerial; plea‑agreement disputes belong against the Commonwealth)
- Doe v. Miller, 886 A.2d 310 (Pa. Cmwlth. 2005) (equal‑protection analysis of Megan’s Law classification under rational‑basis review)
- Barge v. Pennsylvania Board of Probation and Parole, 39 A.3d 530 (Pa. Cmwlth. 2012) (standards for ruling on preliminary objections/demurrer)
- Commonwealth v. Martinez, 147 A.3d 517 (Pa. 2016) (defendant entitled to benefit of bargain via specific performance of plea terms)
- Curtis v. Kline, 666 A.2d 265 (Pa. 1995) (framework for levels of scrutiny in equal protection review)