LeGrande v. Commonwealth of Pennsylvania, Department of Corrections

In LeGrande v. Commonwealth of Pennsylvania, Department of Corrections, 894 A.2d 219 (Pa. Cmwlth. 2006), an inmate filed a petition for review in the nature of mandamus seeking an order directing DOC to recalculate his new sentence in accordance with the trial court's sentencing order. DOC filed preliminary objections challenging, inter alia, this Court's jurisdiction. DOC argued that the Court lacked jurisdiction because the inmate failed to exhaust all available administrative remedies before seeking judicial review. The Court agreed that an inmate had to exhaust all available administrative remedies to preserve the integrity of the administrative process and to allow the agency to address issues within its expertise before judicial review attached, but in LeGrande, the Court were unable to tell from the facts pled whether he had failed to exhaust all of his available administrative remedies and overruled DOC's preliminary objection.