477 F. App'x 861
3rd Cir.2012Background
- In 2004 Sykes was arrested on murder charges and placed in JTVCC general population.
- Media attention grew after the state announced it would seek the death penalty.
- On July 7, 2005, Sykes was moved to the SHU and remained there for at least fifteen months.
- Sykes filed a pro se in forma pauperis § 1983 suit in 2006 alleging lack of due process for SHU confinement.
- District Court dismissed Traci Johnson for failure to serve; others were granted summary judgment on various grounds.
- This court affirms, holding defendants are protected by Eleventh Amendment and qualified immunity; no due process violation shown.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Johnson's personal involvement | Sykes alleges Johnson participated in transfer decision. | Johnson was not involved in the decision; she commented post-transfer. | No personal involvement; liability requires participation. |
| Official-capacity claims and Eleventh Amendment | Officials sued in their official capacities seek injunctive relief and damages. | Official-capacity claims are barred by Eleventh Amendment immunity. | Officials in official capacity are immune; suits barred. |
| Qualified immunity for remaining defendants | Defendants violated clearly established rights by SHU confinement without due process. | Confinement justified by safety, escape risk, and media attention; no clearly established right violated. | Defendants entitled to qualified immunity. |
| Substantive due process / procedural due process | Pretrial SHU housing without procedural protections violated due process. | Reason for transfer and post-transfer actions lacked intentional punishment; no due process violation proven. | No substantial due process violation established. |
Key Cases Cited
- Baraka v. McGreevey, 481 F.3d 187 (3d Cir. 2007) (personal involvement required for liability)
- Betts v. New Castle Youth Dev. Ctr., 621 F.3d 249 (3d Cir. 2010) (Eleventh Amendment immunity for official-capacity claims)
- Camreta v. Greene, 131 S. Ct. 2020 (2011) (qualified immunity depends on clearly established rights)
- McKee v. Hart, 436 F.3d 165 (3d Cir. 2006) (test for clearly established rights in § 1983 cases)
- Ashcroft v. al-Kidd, 131 S. Ct. 2074 (2011) (clear standard for qualified immunity inquiries)
- Stevenson v. Carroll, 495 F.3d 62 (3d Cir. 2007) (procedural due process concerns with SHU housing pre-trial detainees)
- Stevenson v. Carroll (remand discussion), 2011 WL (3d Cir. 2011) (post-transfer procedural protections discussion (contextual))
- Shoats v. Horn, 213 F.3d 140 (3d Cir. 2000) (expanded to address SHU-related due process concerns)