T.X. Wright v. K. Hauffman
T.X. Wright v. K. Hauffman - 1320 C.D. 2016
| Pa. Commw. Ct. | Apr 20, 2017Background
- Prisoner Timothy X. Wright (pro se) sued several Pennsylvania DOC employees alleging violations of his First, Eighth, and Fourteenth Amendment rights related to: opening of legal mail outside his presence; denial/refusal to provide Nation of Islam group worship (Ju’mah) and accommodation to fast in December; and an allegedly improper $1.00 photocopy card charge.
- Wright alleged he filed several grievances with the DOC (including appeals to the central Grievance Appeals office) between April and October 2015 regarding these matters.
- DOC employees filed preliminary objections arguing Wright failed to attach supporting grievance documents, failed to exhaust administrative remedies on the legal-mail and group-worship claims, the photocopy charge claim failed to state a constitutional claim, and the December fast claim was moot after a state-wide policy change.
- The Huntingdon County trial court sustained the preliminary objections and dismissed the complaint, citing lack of documentation showing exhaustion and concluding (without explanation) that Wright failed to raise constitutional violations; it also noted the December-fasting issue was moot.
- The Commonwealth Court vacated and remanded, holding that where preliminary objections raise disputed factual issues about exhaustion the trial court must develop an evidentiary record before dismissal and that the trial court’s cursory conclusion on the Fourteenth Amendment/photocopy claim lacked sufficient explanation for appellate review.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Mootness of group-worship claims (Ju’mah / December fast) | Wright: December-fast claim is moot but Ju’mah/group-worship claim remains live because SCI-Smithfield does not provide Nation of Islam Ju’mah. | DOC: December fast addressed by new policy; Ju’mah claim was dismissed due to failure to show exhaustion, not mootness. | Court: December-fast claim conceded moot; Ju’mah claim cannot be dismissed at pleading stage where DOC raises disputed factual issue about exhaustion — record development required. |
| Exhaustion of administrative remedies | Wright: Alleged he filed multiple grievances and sought redress up the chain. | DOC: Wright did not exhaust or procedurally default as to group-worship and legal-mail claims; pointed to absence of grievance attachments. | Court: Where defendants’ preliminary objections raise a factual dispute about exhaustion, trial court must take evidence (interrogatories, depositions, or hearing) before ruling; remand for record development. |
| Legal mail opened outside presence | Wright: Asserted legal mail marked "Client-Attorney Communications" was opened outside his presence, violating his rights. | DOC: Argued failure to exhaust administrative remedies and raised preliminary objection. | Court: Dismissal for failure to attach grievance documentation was error; factual dispute about exhaustion requires evidentiary proceedings on remand. |
| Photocopy card $1.00 charge / Fourteenth Amendment due process | Wright: $1.00 photocopy card charge contradicts DOC policy (10 cents/page) and deprives property without due process. | DOC: Charge is consistent with policy; claim does not rise to a constitutional violation. | Court: Trial court’s unexplained conclusion that no constitutional claim was raised is insufficient; vacated and remanded for further consideration and explanation. |
Key Cases Cited
- Jones v. Bock, 549 U.S. 199 (exhaustion requirement reduces litigation and builds record)
- LeGrande v. Department of Corrections, 894 A.2d 219 (Pa. Cmwlth. 2006) (inmate must exhaust administrative remedies before suing)
- Pelzer v. Wetzel, 101 A.3d 142 (Pa. Cmwlth. 2014) (if preliminary objections raise factual issue of exhaustion, trial court must develop evidence/hold hearing)