Amos Singleton v. Robinson
679 F. App'x 110
3rd Cir.2017Background
- Amos J. Singleton, a Pennsylvania state prisoner, sued prison staff claiming they destroyed legal materials relevant to his challenges to state and federal convictions and that a grievance coordinator retaliated by arranging his transfer.
- He alleged two counts: (I) denial of access to courts by Lt. Robinson and a John Doe who destroyed an ATF report tied to his federal case; (II) retaliation by Wendy Shaylor via transfer after he filed a grievance.
- The district court dismissed Count II with prejudice for failure to plausibly allege retaliation; Count I was held pending production of the ATF report.
- After the ATF report was produced, Singleton’s court‑appointed counsel moved to withdraw and the district court dismissed Count I with prejudice, finding no actual injury to any nonfrivolous state or federal claim and rejecting allegations the report was falsified.
- Singleton’s motion for reconsideration—seeking an ATF Trace Report and alleging new evidence of falsification—was denied as presenting nothing truly new or nonconclusory; this appeal followed.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether destruction of legal materials denied access to courts | Singleton: destroyed ATF report deprived him of a nonfrivolous challenge to convictions | Defendants: lost materials were not tied to any viable state or federal claim; evidence against him was overwhelming | Dismissal affirmed: no plausible allegation of actual injury to a nonfrivolous claim |
| Whether transfer was retaliatory | Singleton: transfer followed his grievance about destroyed materials, showing retaliation | Defendants: no causal link or facts showing grievance was a substantial/motivating factor | Dismissal affirmed: retaliation not plausibly alleged |
| Whether ATF report was falsified such that reconsideration was warranted | Singleton: report was manipulated; requested court assistance to obtain a different ATF trace report | Defendants: no nonconclusory evidence of falsification; trace request speculative | Denial of reconsideration affirmed: no new, credible evidence of falsification |
| Whether dismissal should be without prejudice or with leave to amend | Singleton: sought further investigation/amendment based on purported new evidence | Defendants: pleaded deficiencies not curable by amendment; counsel withdrew for ethical reasons | District court did not abuse discretion: dismissal with prejudice and denial of further amendment appropriate |
Key Cases Cited
- Huertas v. Galaxy Asset Mgmt., 641 F.3d 28 (3d Cir. 2011) (standard of plenary review for dismissal)
- Ashcroft v. Iqbal, 556 U.S. 662 (2009) (plausibility pleading standard)
- Bell Atl. Corp. v. Twombly, 550 U.S. 544 (2007) (pleading must state a plausible claim)
- Lewis v. Casey, 518 U.S. 343 (1996) (actual injury requirement for access-to-courts claims)
- Rauser v. Horn, 241 F.3d 330 (3d Cir. 2001) (retaliation: burden to show grievance was motivating factor)
- Blystone v. Horn, 664 F.3d 397 (3d Cir. 2011) (limits on motions for reconsideration; definition of "new" evidence)
- Fantone v. Latini, 780 F.3d 184 (3d Cir. 2015) (pro se pleadings must meet Iqbal plausibility standard)