R. Ponder v. PPB

CourtCommonwealth Court of Pennsylvania
DecidedApril 16, 2024
Docket1123 C.D. 2022
StatusUnpublished

This text of R. Ponder v. PPB (R. Ponder v. PPB) 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
R. Ponder v. PPB, (Pa. Ct. App. 2024).

Opinion

IN THE COMMONWEALTH COURT OF PENNSYLVANIA

Rashaad Ponder, : : Petitioner : : v. : No. 1123 C.D. 2022 : Submitted: May 26, 2023 Pennsylvania Parole Board, : : Respondent :

BEFORE: HONORABLE ANNE E. COVEY, Judge HONORABLE MICHAEL H. WOJCIK, Judge HONORABLE STACY WALLACE, Judge

OPINION NOT REPORTED

MEMORANDUM OPINION BY JUDGE WOJCIK FILED: April 16, 2024

Rashaad Ponder (Parolee) petitions for review of the decision of the Pennsylvania Parole Board (Board), which affirmed the Board Action recorded April 27, 2022, denying Parolee credit for time served after being recommitted as a convicted parole violator (CPV). On appeal, Parolee contends that the Board miscalculated the term of his recommitment by one day. After careful review, we dismiss this appeal as moot. Parolee was initially sentenced to serve a 4-year, 2-month to 10-year term of incarceration relating to drug convictions in a State Correctional Institution (SCI). Certified Record (C.R.) at 1-3. Originally, Parolee’s sentence carried a minimum sentence date of March 26, 2015, and a maximum sentence date of January 26, 2021. Id. However, Parolee was paroled and recommitted on a number of occasions. Relevant now, Parolee was granted parole and released on March 3, 2020. Id. In a Board Action recorded March 5, 2020, the Board declared Parolee delinquent effective the day of his release because he failed to report to the district office as required by the conditions of his parole. C.R. at 40. On April 28, 2021, while delinquent, Parolee was arrested by the Oil City Police Department for pending criminal charges in the Venango County Court of Common Pleas (trial court). Id. at 42-43. On that same day, the Board lodged a detainer against him. Id. at 41. According to his supervision history, Parolee was held at the Venango County Jail following his arrest. Id. at 49-50. The Board held a violation hearing there on January 28, 2022, wherein Parolee admitted to violating multiple conditions of his parole.1 Id. at 103. As such, by Board Action recorded February 8, 2022, the Board ordered Parolee to be detained pending the disposition of his criminal charges and to be recommitted as a technical parole violator for nine months. Id. At the time, the Board recalculated Parolee’s maximum sentence date as December 16,

1 The Board observed that Parolee violated the following conditions:

-- CONDITION #1, LEAVING THE DISTRICT WITHOUT PERMISSION.

-- CONDITION #2, CHANGE OF RESIDENCE WITHOUT PERMISSION.

-- CONDITION #7, FAILURE TO REPORT TO THE RENEWAL, INC. #1.

C.R. at 103. 2 2022. Id. The Department of Corrections’ moves report indicates that, on that same day, Parolee was received by SCI-Mercer in error. Id. at 151. Regarding his new criminal charges, Parolee did not post bail prior to trial. C.R. at 156, 168. On February 15, 2022, Parolee was found guilty of flight to avoid apprehension, trial, or punishment, 18 Pa. C.S. §5126. Id. at 168-69. Subsequently, on April 7, 2022, Parolee pleaded guilty to criminal trespass, 18 Pa. C.S. §3503(b)(1)(i), and disorderly conduct, 18 Pa. C.S. §5503(a)(4). Ultimately, the trial court sentenced Parolee to serve 345 days to 23 months, 29 days of confinement in the Venango County Jail. Id. at 156, 168. The trial court credited Parolee with 345 days toward his new sentence, to reflect the period he spent in the Venango County Jail from April 28, 2021, to April 7, 2022. Id. at 138-40. Consequently, Parolee was immediately eligible for parole on his new sentence. Id. The Board scheduled a parole revocation hearing for March 22, 2022; however, Parolee waived his right to a hearing and acknowledged his convictions. C.R. at 110-13. Thereafter, in a Board Action recorded April 27, 2022, the Board notified Parolee of its decision to recommit him as a CPV to serve 12 months of backtime, because of his recent convictions, poor adjustment under supervision, failure to comply with sanctions, his delinquency, prior parole failures, and because he was considered a threat to the community. Id. at 179. The Board also used its discretion to deny awarding Parolee any credit for time spent at liberty, because he absconded while on parole and because of his history of parole failure. Id. at 180. As a result, Parolee’s maximum sentence date was recalculated to November 25, 2023, with parole eligibility as early as April 7, 2023. Id. In a counseled administrative remedies form received on May 31, 2022, Parolee challenged the Board Action recorded April 27, 2022, arguing that the Board

3 “failed to award [Parolee] credit for all time served exclusively to its warrant or while incarcerated.” C.R. at 184. By decision mailed October 5, 2022, the Board denied Parolee’s challenge. C.R. at 195-97. The Board explained that when Parolee was released from confinement on March 3, 2020, 597 days remained due and owing on his original sentence. Id. at 196. “The Board’s decision to recommit him as a [CPV] authorized the recalculation of his maximum sentence date to reflect that he received no credit for the time spent at liberty on parole . . . . [T]his means that he owed 597 days based on the recommitment.” Id. The Board likewise noted that after Parolee’s April 28, 2021 arrest, he was not held exclusively on the Board’s warrant as Parolee never posted bail. Id. As such, the Board explained that he was not entitled to any credit toward his original sentence for the time he was incarcerated from April 28, 2021, to April 7, 2022. Id. Further, under Section 6138(a)(5) of the Prisons and Parole Code, 61 Pa. C.S. §6138(a)(5), the Board noted that Parolee was required to serve his new sentence prior to finishing service on his original sentence. Id. Thus, according to the Board, Parolee did not become available to recommence service on his original sentence until April 7, 2022, the date he was paroled on his new sentence. Id. “Adding 597 days to April 7, 2022 yields a recalculated maximum date of November 25, 2023.” Id. Parolee then filed the instant petition for review of the Board’s decision.2

2 Our review “is limited to determining whether necessary findings of fact are supported by substantial evidence, whether an error of law was committed, or whether the constitutional rights of the parolee were violated.” McNally v. Pennsylvania Board of Probation and Parole, 940 A.2d 1289, 1292 (Pa. Cmwlth. 2008). 4 Parolee’s sole claim on appeal is that the Board failed to give him credit for the single day spent in custody at SCI-Mercer.3 Petitioner’s Brief at 11. However, we need not address the merits of this claim. Ordinarily, “the expiration of a parolee’s maximum term renders an appeal of a Board revocation order moot.” Taylor v. Pennsylvania Board of Probation and Parole, 746 A.2d 671, 674 (Pa. Cmwlth. 2000). As such, we will dismiss an appeal when it becomes impossible for this Court to grant the relief sought. Id. However, we will nevertheless address the merits of such a claim when the issues involved are capable of repetition yet likely to evade review, important to the public interest, or where a party will suffer some detriment without the Court’s decision. Id. Presently, Parolee’s maximum date of November 25, 2023, has passed.4 Because he is no longer serving that sentence, his appeal is moot. Moreover, the credit issues raised in Parolee’s appeal will likely repeat, but will not evade review and have, in fact, been addressed by numerous decisions of this Court and our

3 In his Petition, Parolee also argues that the Board failed to award Parolee credit for the time that he spent at liberty on parole. Petition ¶7. However, in his subsequent brief to this Court, Parolee concedes this argument.

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Related

McNally v. Pennsylvania Board of Probation & Parole
940 A.2d 1289 (Commonwealth Court of Pennsylvania, 2008)
Gaito v. Pennsylvania Board of Probation & Parole
412 A.2d 568 (Supreme Court of Pennsylvania, 1980)
Armbruster v. Pennsylvania Board of Probation & Parole
919 A.2d 348 (Commonwealth Court of Pennsylvania, 2007)
Taylor v. Pennsylvania Board of Probation & Parole
746 A.2d 671 (Commonwealth Court of Pennsylvania, 2000)
Gruzinski v. Department of Public Welfare
731 A.2d 246 (Commonwealth Court of Pennsylvania, 1999)
Hammonds v. Pa. Bd. of Prob. & Parole
143 A.3d 994 (Commonwealth Court of Pennsylvania, 2016)
Pittman v. Pennsylvania Board of Probation & Parole
159 A.3d 466 (Supreme Court of Pennsylvania, 2017)

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Bluebook (online)
R. Ponder v. PPB, Counsel Stack Legal Research, https://law.counselstack.com/opinion/r-ponder-v-ppb-pacommwct-2024.