Alexandra Chavarriaga v. State of NJ Department of Corr
2015 U.S. App. LEXIS 19854
| 3rd Cir. | 2015Background
- Plaintiff Alexandra Chavarriaga, a former New Jersey DOC inmate, alleged that corrections officers unlawfully transferred her between facilities and, during short confinements at New Jersey State Prison (NJSP), denied potable water, clothing, sanitary napkins and related medication, and subjected her to a manual body‑cavity search.
- The District Court granted summary judgment to (and dismissed claims against) several named defendants (including former NJ Attorney General Chiesa, Commissioner Lanigan, and Sgt. Brown) and dismissed claims against unnamed/John/Jane Doe defendants; Chavarriaga appealed.
- Only Chiesa, Lanigan, and Brown were served and participated in the litigation; other named defendants were not served or did not participate.
- The District Court dismissed most claims under Rule 12(b)(6) and granted summary judgment under Rule 56 on others; the Third Circuit reviews both de novo.
- The Third Circuit affirmed summary judgment for Chiesa and Lanigan (no adequate allegations of personal involvement or policymaker liability), affirmed dismissal of transfer‑based due process/equal protection claims, but reversed dismissal as to certain Eighth Amendment and state‑law claims (water deprivation, naked exposure en route to shower, denial of sanitary supplies/medications, and the body‑cavity search) against unidentified defendants and Jane Doe and remanded for further proceedings; Brown retained summary judgment on some claims due to lack of pleading tying her to the deprivations.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether Chiesa and Lanigan are liable under § 1983 (supervisory/policymaker or conspiracy) | Chavarriaga alleged they knew of and approved the misconduct and thus are liable as supervisors/policymakers and conspirators | They lacked personal involvement or actual knowledge; § 1983 requires personal involvement, not respondeat superior | Affirmed for Chiesa and Lanigan — plaintiff failed to plead facts showing personal involvement, knowledge, or policymaker causation |
| Whether transfers among facilities violated due process/equal protection | Transfers were retaliatory and arbitrary, denying liberty/interests | States may place inmates in any facility; no liberty interest in particular placement; transfers rationally related to discipline | Affirmed — transfers did not state a constitutional due‑process or equal‑protection claim |
| Whether deprivation of potable water, denial of sanitary items/meds, and forced naked exposure state Eighth Amendment claims | Denials (three days without potable water; denial of sanitary supplies/meds; forced naked exposure before males) constitute cruel and unusual punishment | Isolated/short deprivations insufficient; summary judgment appropriate; no facts tying supervisors to conduct | Reversed in part — allegations of water deprivation (objective serious harm), naked exposure en route to shower, and denial of sanitary items/meds sufficiently pleaded against unknown defendants (subjective culpability requires proof at trial); Brown granted summary judgment on these for lack of pleading linking her conduct |
| Whether the manual body‑cavity search violated constitutional and state law | The search was non‑routine, painful, performed without required supervisory/medical procedures, and thus was malicious/excessive force and violated NJ regulations | The search was a routine security measure or justified strip/search; Florence governs deference to security policies | Reversed as to Jane Doe and unknown defendants — complaint plausibly alleges a malicious, non‑routine, painful cavity search in violation of the Eighth Amendment and state regulation; Brown not liable absent pleading tying her to the search |
Key Cases Cited
- Celotex Corp. v. Catrett, 477 U.S. 317 (summary judgment standard)
- Anderson v. Liberty Lobby, Inc., 477 U.S. 242 (genuine‑issue standard for summary judgment)
- Farmer v. Brennan, 511 U.S. 825 (deliberate indifference and Eighth Amendment standard)
- Hudson v. McMillian, 503 U.S. 1 (malicious/sadistic use of force violates Eighth Amendment)
- Florence v. Board of Chosen Freeholders, 566 U.S. 318 (deference to prison security policies re: strip searches)
- Wilson v. Seiter, 501 U.S. 294 (Eighth Amendment "minimal civilized measure" test)
- Rode v. Dellarciprete, 845 F.2d 1195 (3d Cir.) (supervisory liability requires personal involvement)
- Nicini v. Morra, 212 F.3d 798 (3d Cir.) (identify right and personal involvement in § 1983 claim)
- Sample v. Diecks, 885 F.2d 1099 (3d Cir.) (liability for policymakers under § 1983)