Anderson v. Horn, 723 A.2d 254 (Pa. Commw. Ct. 1998)

Cases | Anderson v. Horn, 723 A.2d 254 (Pa. Commw. Ct. 1998) | 2018

While the defendant was incarcerated at a state correctional institution, he was found guilty of misconduct for his involvement in a fight with another inmate and for assaulting a correctional officer. The defendant was assessed the total costs incurred for the inmate’s medical treatment, and one-third of the total costs incurred for the treatment of the correctional officer. The Department of Corrections (DOC) withdrew funds from the defendant’s inmate account as restitution. On appeal, the defendant argued that the DOC could not withdraw funds from prisoners’ accounts as restitution for institutional medical expenses because the DOC is a government agency and not a person for the purposes of restitution. The appellate court affirmed the order of the DOC on the merits, finding that the DOC is an administrative agency with the authority to assess damages against an inmate.