In Johnson v. Wetzel, the Pennsylvania Supreme Court ruled that its holding in Bundy v. Wetzel, applies to inmates whose prison inmate accounts were subject to Act 84 deductions without the benefit of the safeguards enunciated in Bundy. Thus, due process required that the Department of Corrections, in response to an administrative grievance which accurately recites that no Bundy process was afforded prior to the first Act 84 deduction, must give the grievant notice of the due process safeguards required by Bundy and a reasonable opportunity to explain why the past and/or intended account deductions should not take place notwithstanding the dictates of Act 84.
