V v. Huntley v. PA DOC, V v. Huntley v. PA DOC

Vincent V. Huntley, an inmate at SCI‑Dallas, requested under the Right to Know Law (RTKL) a signed copy of his "Written Sentencing Order" for Case No. CP‑22‑CR‑3066‑2003.
The Pennsylvania Department of Corrections (Department) granted the request and sent Huntley a copy of the sentencing order signed by the sentencing judge.
Huntley appealed to the Office of Open Records (OOR), claiming the document provided was not the responsive public record he sought and asserting his confinement was unlawful because the trial court failed to provide a proper sentencing order stating the statutory authorization.
The Department submitted an affidavit that no additional responsive records were in its possession; OOR denied Huntley’s appeal, accepting the Department’s evidence that it had produced the sentencing order and had no other records.
Huntley then petitioned this Court pro se, but did not challenge OOR’s finding that the Department produced the signed order; instead he sought collateral relief (remand/habeas relief) attacking the legality of his sentence.
The Commonwealth Court affirmed OOR’s Final Determination, holding that an RTKL appeal is not a proper vehicle to collaterally attack the legality of a criminal sentence and that the Post‑Conviction Relief Act (PCRA) provides the exclusive state remedy for such challenges.

Issue	Huntley’s Argument	Department’s Argument	Held
Whether the Department failed to produce the requested sentencing order	Huntley argued the produced document was not the public record he sought and that a proper sentencing order showing statutory authorization was not provided	Department produced a signed sentencing order and attested no other responsive records existed	Department met its burden; OOR and this Court accepted the affidavit and found no additional records
Whether an RTKL appeal can be used to challenge the legality of Huntley’s confinement	Huntley sought to use the RTKL appeal to obtain relief (remand/habeas) and to declare his sentence invalid for lack of statutory authority	Department argued the RTKL request was satisfied and that sentencing legality is not within RTKL scope	RTKL is not a vehicle for collateral attack on a criminal sentence; such claims must proceed under the PCRA or other proper remedies
Whether the court could transfer the RTKL appeal to a trial court to allow a collateral challenge	Huntley asked the Court to remand/transfer for habeas/PCRA‑type relief	Department opposed transfer; Court noted procedural and pleading requirements of PCRA	Court declined to transfer; no authority permits transfer and the petition lacked required PCRA pleadings

Sherry v. Radnor Twp. Sch. Dist., 20 A.3d 515 (Pa. Cmwlth. 2011) (affidavits can supply sufficient evidentiary support under the RTKL)
Moore v. Office of Open Records, 992 A.2d 907 (Pa. Cmwlth. 2010) (RTKL appeal is not the proper forum to challenge continued confinement)
McGowan v. Pa. Dep’t of Envtl. Prot., 103 A.3d 374 (Pa. Cmwlth. 2014) (acceptance of agency affidavits absent evidence of bad faith)
Office of the Governor v. Scolforo, 65 A.3d 1095 (Pa. Cmwlth. 2013) (standards for evidentiary sufficiency of agency affidavits in RTKL matters)
Bowling v. Office of Open Records, 75 A.3d 453 (Pa. 2013) (purpose and scope of the RTKL)
Commonwealth v. Hall, 771 A.2d 1232 (Pa. 2001) (PCRA is the exclusive state remedy for prisoners challenging allegedly illegal sentences)