Lewis Watkins v. Pennsylvania Parole Board

Summary

The Pennsylvania Commonwealth Court affirmed the Pennsylvania Parole Board’s recommitment of Lewis Watkins as a technical parole violator after his unsuccessful discharge from a community corrections center. The court held that substantial evidence supported the Board’s finding that Watkins violated the center’s rules and that the Board’s credibility determinations were not reviewable on appeal. The court also rejected Watkins’ due process claim, concluding that he had notice and a meaningful opportunity to present evidence and was not entitled to reopen the record for a second hearing.

Holdings

1. Substantial evidence supported the Board's finding that Watkins violated the rules of Create House and consequently violated the terms of his parole.
2. The Board did not violate Watkins's due process rights because he received notice of his rights and a meaningful opportunity to be heard, and due process did not guarantee a second hearing or reopening of the record to present additional evidence.

Questions Presented

1. Whether substantial evidence supported the Pennsylvania Parole Board's finding that Watkins violated the terms of his parole.
2. Whether the Board violated Watkins's procedural due process rights by failing to permit him to present additional exculpatory evidence after the violation hearing.

Disposition

affirmed