Can the Department of Corrections Deduct Prisoners Funds to Pay Fines ?
In Boyd v. Department of Corrections, 831 A.2d 779, 783 (Pa. Cmwlth. 2003), the inmate did not dispute that the sentencing court therein had imposed upon him certain fines, costs, and restitution.
The relevant dispositive issue in that matter was whether, given that undisputed imposition of fines, costs, and restitution, the Department of Corrections could rely upon the Court Commitment Order in effecting the deductions.
The Court held:
Because, in this case, Boyd does not dispute that the sentencing court imposed fines, costs and restitution upon him, but instead, only argues that the Department of Corrections may not deduct funds for such purposes without a court order authorizing the "act" of deducting those funds, his argument must fail.
Even though the Court Commitment order, Form DC-300B, was completed on the court's behalf by the clerk and was not signed by the sentencing judge, the Department of Corrections did not err in relying on that form which indicated that Boyd had been ordered to pay $ 5,000.00 in fines, $ 335.20 in costs and $ 3,240.00 in restitution by the sentencing court. See Abraham v. Department of Corrections, 150 Pa. Commw. 81, 615 A.2d 814 (Pa. Cmwlth. 1992), affirmed, 535 Pa. 122, 634 A.2d 214 (1993), overruled on other grounds by Commonwealth v. Tilghman, 543 Pa. 578, 673 A.2d 898 (1996). Boyd, 831 A.2d at 782-783.