Commonwealth Court dismisses Houtzdale inmate’s lawsuit
Edwards sought greater access to prison’s law library, recreation
The Pennsylvania Commonwealth Court has dismissed a lawsuit filed by an inmate of the State Correctional Institution in Houtzdale who sought greater access to the prison’s law library and recreational facilities.
The inmate, Nicholas D. Edwards, 46, who is serving a life sentence, filed a petition against several officials of the prison and the attorney general at the time, Josh Shapiro, in which he asked for a court injunction that would allow him to spend up to six hours a week in the law library and allow him to have access to the “main” recreation yard at Houtzdale.
As Edwards explained in his petition, he is limited to three, one-hour sessions in the library each week.
He maintained that policy implemented by the Pennsylvania Department of Corrections guarantees him six hours of library time each week.
He contended that recently he lost one of his legal cases because he did not have time to prepare his argument.
In his second issue, Edwards stated that he is denied access to what is known as the “main yard” where the general population of the prison has access to recreational activities.
He explained the main yard has a track, water fountains, bathrooms and athletic fields.
Edwards, however, is restricted to a recreational facility that contains only weights and basketball courts.
His petition argued that lack of access to the main yard “poses risks to his mental health, and physical wellbeing.”
Lack of exercise, he stated, is affecting his overall health.
He contended that his limited access to the main exercise area of the prison violates the First, Eighth and Fourteenth Amendments to the Constitution.
The prison officials and the Attorney General answered the Edwards lawsuit by contending his claims have already been addressed by two trial courts which ruled that he failed to prove negligence on the part of the respondents.
In a ruling Monday, the Commonwealth Court refused further hearing in the matter, noting it lacked jurisdiction.
“Thus, whenever a court discovers it lacks jurisdiction over the subject matter or a cause of action, it is compelled to dismiss the matter under all circumstances,” according to Monday’s opinion.
For the court to have jurisdiction, “The Commonwealth or one of its officers must be an indispensable party to the action,” the opinion explained.
The court added that the Edwards lawsuit does not name as respondents any officials who created the alleged policies he complains about.
The opinion noted Edwards does not challenge the constitutionality of DOC’s policies and has not named DOC’s secretary or any other DOC official as respondents.
“Individual DOC employees at state correctional institutions (like those named as respondents by Edwards) do not have statewide policymaking authority and are not ‘Commonwealth officers’ for purposes of our original jurisdiction,” the opinion concluded.
Edwards did name the attorney general as a respondent, but the petition filed by the inmate failed to explain “how the office of (Attorney General) had any impact on, or authority over, Edwards’ access to the law library or main recreation yard,” the Commonwealth Court opinion continued.
Lacking jurisdiction to hear the case, the opinion closed by noting Edwards’ quest for an injunction was moot, or of no significance at this point.
Edwards, a native of Philadelphia, is serving a life sentence for murder imposed 23 years ago.


