H.D. v. Department of Public Welfare

In H.D. v. Department of Public Welfare, 751 A.2d 1216 (Pa. Cmwlth. 2000), the Court explained that failure to timely appeal an administrative agency's action constitutes a jurisdictional defect and that the time for filing an appeal may not be extended as a matter of grace or mere indulgence. DPW notes that under 55 Pa. Code 275.2, a request for a hearing is an expression by "the client or the person acting for him" and that under Chichester Kinderschool v. Department of Public Welfare, 862 A.2d 119 (Pa. Cmwlth. 2004), appeals and hearings are authorized only for public assistance applicants or their authorized representatives.