Williams, J. v. Wetzel, J., Aplts., 232 A.3d 652

Appellee, a state prisoner, was discovered with several pounds of sugar hidden in his boots after a search when leaving his prison kitchen job and was removed from that employment following a unit-manager support-team hearing at his cell door.
Appellee filed a petition for review in the Commonwealth Court (in the nature of mandamus), alleging DOC failed to follow prison misconduct procedures (37 Pa. Code §93.10; DC‑ADM 816) and thus denied him due process.
The Commonwealth Court granted declaratory and injunctive relief, directing the Department of Corrections to comply with the applicable procedural regulations.
A dissenting Commonwealth Court judge argued, relying on Bronson, that the Commonwealth Court lacks original jurisdiction to decide prison due-process claims when the inmate does not assert a constitutionally protected liberty or property interest.
The Pennsylvania Supreme Court held that Appellee never asserted a protected liberty or property interest (and in fact admitted taking the sugar), and that removal from prison employment does not constitute a protected interest warranting due-process protections.
The Supreme Court reversed the Commonwealth Court’s order and remanded with instructions to dismiss the petition for review for lack of jurisdiction.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the Commonwealth Court has original jurisdiction to hear Appellee's due-process claim without an asserted constitutionally protected interest	Williams argued DOC’s failure to follow its regulations deprived him of due process and sought enforcement of those procedures	DOC (and intervening authority) argued jurisdiction is lacking absent a protected liberty or property interest	Court held Commonwealth Court lacks original jurisdiction where no constitutionally protected interest is asserted; petition dismissed
Whether removal from prison employment gives rise to a protected liberty/property interest triggering due-process protections	Williams contended the procedures in the regulations conferred a right to the process he was denied	DOC argued prison employment is an administrative matter and inmates have no constitutional right to continue job assignments	Court held removal from prison employment is not a constitutionally protected interest; no due-process claim on that basis

Bronson v. Central Office Review Committee, 554 Pa. 317 (Pa. 1998) (Commonwealth Court lacks original jurisdiction over prisoner due‑process claims absent an asserted liberty or property interest)
Sandin v. Conner, 515 U.S. 472 (U.S. 1995) (due process protects only liberty interests created by atypical and significant hardships in relation to ordinary prison life)
Bush v. Veach, 1 A.3d 981 (Pa. Cmwlth. 2010) (recognized right to regulatory procedures but did not address Commonwealth Court jurisdiction under Bronson)
Dantzler v. Wetzel, 218 A.3d 519 (Pa. Cmwlth. 2019) (held inmate must assert a constitutionally protected liberty or property interest to state a due‑process claim in Commonwealth Court)