Washington v. Pa. Department of Corrections – Pa. Supreme Court – December 19, 2023
Majority https://www.pacourts.us/assets/opinions/Supreme/out/J-32-2023mo%20-%20105773995249529739.pdf?cb=1
Concurring https://www.pacourts.us/assets/opinions/Supreme/out/J-32-2023co%20-%20105773995249530389.pdf?cb=1
Dissenting https://www.pacourts.us/assets/opinions/Supreme/out/J-32-2023do%20-%20105773995249529957.pdf?cb=1
Held: Prisoner’s right to procedural due process violated when it increased the rate of deductions from his prison pay from 20% to 25% without pre-deprivation notice and hearing.
This was the case even though the increased deduction resulted from a statutory change, because the prison policy about deductions was not universal or even near-universal in application, but rather was applied differently to different inmates, based, inter alia, on their individual financial circumstances.
