Feliciano v. PA Dep’t of Corr.

In Feliciano v. PA Dep’t of Corr., the Pennsylvania Commonwealth Court reset the standard by which the court can act in its original jurisdiction to potentially redress an alleged constitutional violation suffered by a prisoner at the hands of his jailers. Here, an inmate was found guilty of testing positive for a controlled substance after an internal prison hearing. But the inmate argued to the Commonwealth Court that his hearing violated due process because he was not provided with the paperwork regarding the urine sample before the hearing. The Court adopted the three-element test used in Aref v. Lynch, 833 F.3d 242 (D.C. Cir. 2016), to determine “whether an inmate is entitled to procedural due process in the context of an administrative determination that affects his carceral housing situation.” Here, the inmate could not satisfy the test, and the Court thus sustained the DOC’s preliminary objections.

Feliciano