In Pettit v. Michael Namie, Controller of Washington County, 931 A.2d 790 (Pa. Cmwlth. 2007), the district attorney, John Pettit, was sued for violating a citizen's civil rights by depriving him of the use of his property that had been seized during an arrest and subsequently forfeited pursuant to Section 6801 of the Judicial Code, 42 Pa. C.S. 6801, commonly known as the Controlled Substances Forfeiture Act. Pettit failed to comply with a court order requiring him to return the property. Pettit was found liable, paid the judgment and then filed an action in mandamus and for declaratory judgment against the county commissioners and controller demanding indemnification for payment of the judgment entered against him and attorney's fees, costs and expenses incurred in defending his official actions during post-trial proceedings during which the county withdrew its representation. The Court held that although reckless conduct may have been proven, the county failed to prove the element of willful misconduct which is necessary to disqualify an employee acting within the scope of employment from receiving indemnification.