Is the Assessment of Compensatory and Punitive Damages Outside the Scope of Declaratory Judgements Act ?

In Mueller v. State Police Headquarters, 110 Pa. Commw. 265, 532 A.2d 900 (Pa.Commw. 1987), a prisoner sought both mandamus and declaratory relief, claiming that Department of Corrections officials violated their duty to file or investigate criminal complaints after Mueller alleged criminal conduct on the part of several corrections officers. The Commonwealth Court addressed the issue whether a prisoner seeking a declaratory judgment as to his rights under a Department of Corrections Administrative Directive and as to the legal effect of certain actions by Department personnel could also seek an assessment of compensatory and punitive damages under the Act. Mueller, 532 A.2d at 905. Finding that assessment of compensatory and punitive damages was outside the scope of the Declaratory Judgments Act (DJA), the Commonwealth Court held that the Act did not allow such a claim for damages. Id.