Summary
The Supreme Court of Pennsylvania held that the Commonwealth Court lacked original jurisdiction over a prisoner's due-process challenge because he failed to identify a constitutionally protected liberty or property interest. The court explained that inmates have no constitutionally protected interest in maintaining prison employment and reversed the Commonwealth Court's order granting declaratory and injunctive relief. The matter was remanded for dismissal of the petition for review.
Holdings
- The Commonwealth Court lacks original jurisdiction to entertain a prisoner's due-process challenge to prison officials' actions when the prisoner fails to assert a constitutionally protected liberty or property interest.
- An inmate has no constitutionally protected liberty or property interest in maintaining a prison employment assignment.
Questions Presented
- Whether the Commonwealth Court had original jurisdiction over Williams's due-process challenge when he did not identify a constitutionally protected liberty or property interest.
- Whether an inmate has a constitutionally protected liberty or property interest in maintaining a prison employment assignment.
Disposition
reversed_and_remanded
Cases Cited (12)
- Williams v. Wetzel, 222 A.3d 49, 50-54 (Pa. Cmwlth. 2019)(followed procedurally; reversed in result)
- Dantzler v. Wetzel, 218 A.3d 519 (Pa. Cmwlth. 2019)(approved)
- Bronson v. Central Office Review Committee, 554 Pa. 317, 721 A.2d 357 (1998)(followed)
- Sandin v. Conner, 515 U.S. 472, 484-85, 115 S. Ct. 2293, 2300-01 (1995)(applied)
- Bush v. Veach, 1 A.3d 981, 984 (Pa. Cmwlth. 2010)(criticized)
- DEP v. Cromwell Twp., Huntingdon Cty, 613 Pa. 1, 12, 32 A.3d 639, 646 (2011)(followed)
- Fenati v. DOC, No. 56 M.D. 2017, 2017 WL 5580069, at *3 (Pa. Cmwlth. Nov. 21, 2017)(followed)
- Watson v. DOC, 567 F. App'x 75, 78 (3d Cir. 2014) (per curiam)(followed)
- Johnson v. Rowley, 569 F.3d 40, 44 (2d Cir. 2009)(followed)
- Dellis v. Corr. Corp. of Am., 257 F.3d 508, 511 (6th Cir. 2001)(followed)
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Cited In (0)
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Court Document
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