C. Talbert v. Com. of PA, PA Commission on Sentencing

CourtCommonwealth Court of Pennsylvania
DecidedJanuary 10, 2025
Docket458 M.D. 2023
StatusUnpublished

This text of C. Talbert v. Com. of PA, PA Commission on Sentencing (C. Talbert v. Com. of PA, PA Commission on Sentencing) 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
C. Talbert v. Com. of PA, PA Commission on Sentencing, (Pa. Ct. App. 2025).

Opinion

IN THE COMMONWEALTH COURT OF PENNSYLVANIA

Charles Talbert, : Petitioner : : v. : No. 458 M.D. 2023 : Commonwealth of Pennsylvania, : Submitted: November 7, 2024 Pennsylvania Commission on : Sentencing, : Respondents :

OPINION NOT REPORTED

MEMORANDUM OPINION PER CURIAM FILED: January 10, 2025

Charles Talbert,1 pro se, has filed an amended Petition for Review (Petition) in this Court’s original jurisdiction against the Commonwealth of Pennsylvania2 (Commonwealth) and the Pennsylvania Commission (Commission) on Sentencing. The Commission has filed preliminary objections, and Talbert has filed an application for summary relief. After careful review, we sustain the Commission’s

1 Courts have labeled Talbert a serial litigant. Talbert v. City of Philadelphia, No. 21-4303, 2021 WL 4552390 (E.D. Pa., filed Oct. 5, 2021); accord Talbert v. Carney, No. 18-1620, 2018 WL 4839038 (E.D. Pa., filed Oct. 3, 2018); Talbert v. Carney, No. 18-1620, 2018 WL 3520676, *1 (E.D. Pa., filed July 20, 2018) (noting filing of “almost three dozen lawsuits over the past couple of years”). See also Talbert v. Little, 293 A.3d 1242 (Pa. Cmwlth. 2023).

2 Talbert did not serve the Petition on the Commonwealth. See August 2, 2024 order denying Talbert’s Motion for Default Judgment. Therefore, the Commonwealth is not participating. We note that, other than naming the Commonwealth in the caption, Talbert does not set forth the specific factual and legal bases for his claims against the Commonwealth. preliminary objections, dismiss the Petition and dismiss Talbert’s application for summary relief as moot. I. Background Talbert, who is incarcerated at the State Correctional Institution at Fayette, initiated this action on October 16, 2023, with the filing of a complaint that was later amended and refiled as the operative Petition. The Petition contains two counts. Count I is a claim for “Conspiracy to Violate the State Constitution.” Count II is a claim for “Fraud in Equity.” Under a heading labeled “Statement of Facts,” Talbert avers that the Commonwealth and Commission “have established and maintained a widespread practice of transgressing their constitutional power, by and through [their] criminal processes and laws that inflict cruel and unusual punishments against the citizens of Pennsylvania.” (Petition, ¶ 21.) He further alleges that the Commonwealth and Commission have

exceeded [their] constitutional police power by adopting, promulgating, implementing and enforcing state laws on sentencing which impose excessive years of total confinement as punishment, which is unnecessarily disproportionate to the offense, disproportionate in use upon people of color, too severe compared to the general ideas of dignity decency, and civilized standards, encourages hatred towards society and intended to degrade and dehumanize the citizens of Pennsylvania. (Petition, ¶ 22.) He alleges that “[t]he Commission’s rules on sentencing promote equitable fraud by “deceiving the public” into believing that “excessive years in prison” as a sentence “protects the public,” “deters wrongful behavior,” and “helps rehabilitative offenders.” Talbert claims as a result of these alleged acts, he has been subjected to cruel and unusual punishment. (Petition, ¶¶ 25-26.)

2 As relief, Talbert demands damages and an injunction directing the Commonwealth and Commission “to reform [their] rules and statutes that establish[] [the] sentencing guidelines and how prisoners receive programming and rehabilitative services.” (Petition, ¶¶ 28-29.) On October 26, 2023, Talbert filed an application for summary relief, asserting that he is entitled to judgment in his favor as a matter of law. On February 20, 2024, the Commission filed preliminary objections to the Petition on the grounds that Talbert has failed to state a claim upon which relief can be granted and the Commission is immune from suit under the doctrines of sovereign and legislative immunity. II. Discussion We begin by reiterating that in ruling on preliminary objections in the nature of a demurrer, this Court must accept as true all well-pleaded material allegations in the Petition, as well as all inferences reasonably deduced therefrom. Buoncuore v. Pennsylvania Game Commission, 830 A.2d 660, 661 (Pa. Cmwlth. 2003). However, we “need not accept as true conclusions of law, unwarranted inferences from facts, argumentative allegations, or expressions of opinion.” Id. We may sustain preliminary objections only when the law makes clear that the petitioner cannot succeed on the claim, and we must resolve any doubt in favor of the petitioner. Savage v. Storm, 257 A.3d 187, 191 (Pa. Cmwlth. 2021). A. Mandamus The Commission was created in 1978 by the General Assembly, in part for the purpose of promulgating guidelines to be considered by courts in imposing sentences. Commonwealth v. Sessoms, 532 A.2d 775, 776 (Pa. 1987) (recognizing that the Commission is a “legislative agency”); 42 Pa. C.S. § 2151.2 (“[C]ommission is

3 continued as an agency of the General Assembly”). It is a “legislative agency” of the General Assembly and consists of 11 members – four from the legislature, four from the judiciary and three appointed by the Governor. 42 Pa. C.S. § 2152. The Commission is empowered, inter alia, to collect and disseminate information regarding the sentencing process, sentences actually imposed and the effectiveness of sentences imposed; to make recommendations to the legislature concerning modification or enactment of sentencing and correctional statutes; to enter into cooperative arrangements with other governmental agencies; to conduct research, receive testimony and publish data on the sentencing process; and to serve as a clearing house, information center and consultant regarding sentencing practices. 42 Pa. C.S. § 2153. Pursuant to rules and regulations, the Commission has the power to, inter alia, adopt guidelines for sentencing within the limits established by law. 42 Pa. C.S. § 2154. In this case, Talbert is asking the Court to compel the Commission to reform the manner in which it adopts sentencing guidelines because he believes that the sentencing guidelines, in general, inflict cruel and unusual punishments against the citizens of Pennsylvania. The factual averments in Talbert’s Petition are not legally sufficient to state a cause of action for mandamus. A writ of mandamus is an extraordinary remedy which compels the performance of a ministerial act or mandatory duty. Pennsylvania Dental Association v. Insurance Department, 516 A.2d 647 (Pa. 1986). A ministerial act is “one which a public officer is required to perform upon a given state of facts and in a prescribed manner in obedience to the mandate of legal authority.” Rose Tree Media School District v. Department of Public Instruction, 244 A.2d 754, 755 (Pa. 1968). A writ of mandamus may be issued only where there is a clear legal right in the plaintiff, a corresponding duty in the defendant, and a want of any other appropriate and adequate

4 remedy. Pennsylvania State Association of County Commissioners v. Commonwealth, 681 A.2d 699 (Pa. 1996). The adoption of sentencing guidelines is discretionary and not a ministerial act.

Free access — add to your briefcase to read the full text and ask questions with AI

Related

Logan v. Lillie
728 A.2d 995 (Commonwealth Court of Pennsylvania, 1999)
Pennsylvania Dental Ass'n v. Commonwealth Insurance Department
516 A.2d 647 (Supreme Court of Pennsylvania, 1986)
Rose Tree Media School District v. Department of Public Instruction
244 A.2d 754 (Supreme Court of Pennsylvania, 1968)
Commonwealth v. Sessoms
532 A.2d 775 (Supreme Court of Pennsylvania, 1987)
Pennsylvania State Ass'n of County Commissioners v. Commonwealth
681 A.2d 699 (Supreme Court of Pennsylvania, 1996)
Buoncuore v. Pennsylvania Game Commission
830 A.2d 660 (Commonwealth Court of Pennsylvania, 2003)
League of Women Voters of Pennsylvania v. Commonwealth
177 A.3d 1000 (Commonwealth Court of Pennsylvania, 2017)

Cite This Page — Counsel Stack

Bluebook (online)
C. Talbert v. Com. of PA, PA Commission on Sentencing, Counsel Stack Legal Research, https://law.counselstack.com/opinion/c-talbert-v-com-of-pa-pa-commission-on-sentencing-pacommwct-2025.