Wallace v. Pennsylvania Board of Probation and Parole

In Wallace v. Pennsylvania Board of Probation and Parole, 119 Pa. Commw. 508, 548 A.2d 1291 (Pa. Commw. Ct. 1988), a parolee asserted that he was denied due process because he was not provided with advance notice of his parole revocation hearing, but this Court held that the parolee waived his due process challenge. Wallace, 548 A.2d at 1293. In so holding, the Court noted that the parolee did not raise this issue at his parole revocation hearing and then explained that "where a parolee fails to raise an issue before the Board, it is considered waived and cannot be raised for the first time on judicial review." Id. at 1293 (citing Section 703(a) of the Administrative Agency Law, 2 Pa. C.S. 703(a)).