A. McFalls v. 38th Judicial District, Hon. C. Carluccio

CourtCommonwealth Court of Pennsylvania
DecidedJune 23, 2025
Docket4 M.D. 2021
StatusUnpublished

This text of A. McFalls v. 38th Judicial District, Hon. C. Carluccio (A. McFalls v. 38th Judicial District, Hon. C. Carluccio) is published on Counsel Stack Legal Research, covering Commonwealth Court of Pennsylvania primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
A. McFalls v. 38th Judicial District, Hon. C. Carluccio, (Pa. Ct. App. 2025).

Opinion

IN THE COMMONWEALTH COURT OF PENNSYLVANIA

Amy McFalls, Jason Crunetti, Vincent : Esposito, Gregory Jackson, and Brenda : Lacy, on behalf of themselves and all : persons similarly situated, : Petitioners : : v. : : 38th Judicial District, Hon. Carolyn T. : Carluccio, President Judge (in her : official capacity), Michael R. Kehs, Esq. : Court Administrator (in his official : capacity), and Lori Schreiber, Clerk of : Courts (in her official capacity), : No. 4 M.D. 2021 Respondents : Argued: March 5, 2025

BEFORE: HONORABLE RENÉE COHN JUBELIRER, President Judge HONORABLE ANNE E. COVEY, Judge HONORABLE MICHAEL H. WOJCIK, Judge HONORABLE CHRISTINE FIZZANO CANNON, Judge HONORABLE LORI A. DUMAS, Judge HONORABLE STACY WALLACE, Judge HONORABLE MATTHEW S. WOLF, Judge

OPINION NOT REPORTED

MEMORANDUM OPINION BY JUDGE FIZZANO CANNON FILED: June 23, 2025

This is a Petition for Review (Petition) brought as a class action in our original jurisdiction. Amy McFalls, Jason Crunetti, Vincent Esposito, Gregory Jackson, and Brenda Lacy, on behalf of themselves and all persons similarly situated (Petitioners), challenge the propriety of court costs calculated and imposed on defendants convicted of crimes in the Court of Common Pleas of Montgomery County (Common Pleas) from January 1, 2008 forward. Respondents are the 38th Judicial District, i.e., Common Pleas; the Honorable Carolyn T. Carluccio, President Judge, in her official capacity; Michael R. Kehs, Esquire, Court Administrator, in his official capacity; and Lori Schreiber, Clerk of Courts, in her official capacity. Common Pleas, the President Judge, and the Court Administrator are jointly referenced here as Judicial Respondents. Currently before this Court are cross-applications for summary relief. Also before the Court is a Joint Request for Referral to Mediation (Mediation Request) filed by Judicial Respondents. For the reasons discussed below, we grant Judicial Respondents’ application for summary relief, deny the Clerk of Courts’ application for summary relief, deny Petitioners’ application for summary relief, and dismiss the Mediation Request as moot.

I. Background Petitioners allege that the method by which court costs are calculated and imposed against persons convicted of crimes in Common Pleas is not authorized by law and is arbitrary, without proper notice, and duplicative, such that it violates the due process and equal protection rights of convicted persons. Petitioners also allege that the failure to provide a convicted criminal with an itemized list of costs at the time of sentencing violates the convicted person’s due process rights. More specifically, Count I of the Petition asserts that the imposition of duplicative costs in criminal matters is not statutorily authorized and is ultra vires. Count II alleges that Petitioners’ due process rights under article I, sections 1 and 91 of the Pennsylvania

1 Article I, section 1 of the Pennsylvania Constitution provides: “All men are born equally free and independent, and have certain inherent and indefeasible rights, among which are those of

2 Constitution are violated by the failure to provide adequate notice regarding the imposition of costs, a proper opportunity to be heard, and an explanation of how the assessed costs can be challenged. Count III alleges, pursuant to 42 U.S.C. § 1983,2

enjoying and defending life and liberty, of acquiring, possessing and protecting property and reputation, and of pursuing their own happiness.” Pa. Const. art. I, § 1.

Article I, section 9 of the Pennsylvania Constitution provides:

In all criminal prosecutions the accused hath a right to be heard by himself and his counsel, to demand the nature and cause of the accusation against him, to be confronted with the witnesses against him, to have compulsory process for obtaining witnesses in his favor, and, in prosecutions by indictment or information, a speedy public trial by an impartial jury of the vicinage; he cannot be compelled to give evidence against himself, nor can he be deprived of his life, liberty or property, unless by the judgment of his peers or the law of the land. The use of a suppressed voluntary admission or voluntary confession to impeach the credibility of a person may be permitted and shall not be construed as compelling a person to give evidence against himself.

Pa. Const. art. I, § 9. 2 Section 1983 provides:

Every person who, under color of any statute, ordinance, regulation, custom, or usage, of any State or Territory or the District of Columbia, subjects, or causes to be subjected, any citizen of the United States or other person within the jurisdiction thereof to the deprivation of any rights, privileges, or immunities secured by the Constitution and laws, shall be liable to the party injured in an action at law, suit in equity, or other proper proceeding for redress, except that in any action brought against a judicial officer for an act or omission taken in such officer’s judicial capacity, injunctive relief shall not be granted unless a declaratory decree was violated or declaratory relief was unavailable. For the purposes of this section, any Act of Congress applicable exclusively to the District of Columbia shall be considered to be a statute of the District of Columbia.

42 U.S.C. § 1983.

3 that the individual Respondents have violated Petitioners’ federal due process rights. Count IV alleges that the arbitrary manner in which costs have been imposed violates Petitioners’ equal protection rights under article I, sections 1 and 263 of the Pennsylvania Constitution. Count V alleges, pursuant to 42 U.S.C. § 1983, that the individual Respondents have violated Petitioners’ federal equal protection rights.4 The Petition seeks relief in the form of a declaration that the imposition of costs on multiple counts in a single criminal proceeding against a single criminal defendant is unlawful and that such charges are null and void. The Petition seeks a further declaration that Common Pleas cannot impose costs on a criminal defendant unless it provides an itemized bill of costs to the defendant and defense counsel at sentencing. The Petition also seeks injunctive relief directing Respondents to cease imposing duplicative costs, cease any collection activities relating to such costs that remain unpaid, adjust all unpaid balances to remove duplicative costs, and provide notice of the adjustments to the affected defendants. The Petition further seeks an injunction directing Petitioners to develop, within 30 days, a program of effective and timely notice of costs imposed, including an itemized bill of costs provided to the defendant and defense counsel at sentencing, correlating the costs to the criminal charges, setting forth the statutory authorization for each item of costs imposed, as well as notice to the defendant and counsel of the right and procedural means to challenge the costs. The Petition additionally seeks an order directing Respondents

3 Article I, section 26 of the Pennsylvania Constitution provides: “Neither the Commonwealth nor any political subdivision thereof shall deny to any person the enjoyment of any civil right, nor discriminate against any person in the exercise of any civil right.” Pa. Const. art. I, § 26.

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A. McFalls v. 38th Judicial District, Hon. C. Carluccio, Counsel Stack Legal Research, https://law.counselstack.com/opinion/a-mcfalls-v-38th-judicial-district-hon-c-carluccio-pacommwct-2025.