W. Long v. K.D. Kyler
1920 C.D. 2015
| Pa. Commw. Ct. | Aug 26, 2016Background
- Wendell Long, an inmate at SCI-Huntingdon, was charged with lewd conduct on May 6, 2000; an initial hearing dismissed the charge without prejudice for lack of evidence. A second charge based on the same incident led to a hearing on May 11, 2000, where Long was found guilty and received 30 days disciplinary custody, loss of job, loss of honor block status, and loss of single cell status.
- Long appealed administratively (Program Review Committee, Superintendent Kenneth Kyler, Chief Hearing Officer) and later filed a Petition for Relief under the Pennsylvania PLRA seeking declaratory relief, expungement of the misconduct conviction, restoration of lost privileges, and compensatory and punitive damages, alleging falsified evidence and denial of representation/witnesses.
- Kyler filed preliminary objections in the nature of a demurrer; the case lay dormant for over a decade before the trial court allowed briefing and then granted the preliminary objections, dismissing Long’s petition.
- The Commonwealth Court reviewed the appeal de novo and accepted Long’s well-pled facts as true but not his legal conclusions.
- The court determined Long’s claims challenged internal prison operations and misconduct determinations, areas beyond the court’s jurisdiction, and found Long failed to allege sufficient facts to show a due process violation (he did not identify the witnesses he was denied or show prejudice).
- The court held that the sanctions (30 days in custody, loss of job, housing changes) did not implicate protected liberty interests under precedent and affirmed the dismissal.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Jurisdiction over prison misconduct appeals | Long sought judicial relief (expungement and invalidation) from misconduct conviction and sanctions | Kyler argued such challenges implicate internal prison operations beyond the court’s appellate/original jurisdiction | Court: Claims are nonjusticiable here; prison disciplinary appeals are not within this Court’s jurisdiction (dismissed) |
| Procedural due process at misconduct hearing | Long claimed denial of representation and denial of witnesses violated due process | Kyler argued proper disciplinary procedures apply and Long did not identify witnesses or prejudice | Court: Due process requires notice, statement of reasons, and qualified right to call witnesses; Long failed to identify witnesses or show prejudice, so no due process violation alleged |
| Protected liberty interest in sanctions (segregation, job, housing) | Long argued sanctions were unconstitutional and deprived him of rights | Kyler maintained these sanctions are within DOC discretion and do not create a protected liberty interest | Court: 30 days in restricted housing, loss of job, and housing/job status do not implicate a protected liberty interest; no relief warranted |
| Availability of monetary damages for prison disciplinary decisions | Long demanded compensatory and punitive damages for alleged constitutional violations | Kyler contended Long’s claims are not cognizable given jurisdictional and substantive defects | Court: Because underlying claims are nonjusticiable or inadequately pled, damages claims fail |
Key Cases Cited
- Bronson v. Central Office Review Comm., 721 A.2d 357 (Pa. 1998) (internal prison operations and inmate misconduct appeals are not within the judiciary’s appellate jurisdiction)
- Brown v. Pennsylvania Dep’t of Corr., 913 A.2d 301 (Pa. Cmwlth. 2006) (decisions on misconduct charges are beyond this Court’s jurisdiction)
- Balletta v. Spadoni, 47 A.3d 183 (Pa. Cmwlth. 2012) (standard of review for preliminary objections in nature of demurrer)
- Sandin v. Conner, 515 U.S. 472 (U.S. 1995) (short-term segregated confinement did not create a protected liberty interest)