B. Rawlings v. John Wetzel, Secretary of D.O.C. Robert Gilmore, Superintendent at SCI-Greene, 562 M.D. 2016

Background

Petitioner Brehon Rawlings, an inmate at SCI‑Greene with treated anxiety/depression (a "C code"), was sentenced to RHU disciplinary confinement after misconduct convictions in 2016.
Rawlings alleges DOC placed him in RHU without mental‑health assessment, failed to note his stability code on the misconduct report, and ignored a Disability Rights Network agreement requiring periodic mental‑health reviews.
He exhausted grievance remedies and sought relief under 42 U.S.C. §1983 for Eighth and Fourteenth Amendment violations and under the ADA.
DOC filed preliminary objections (demurrer), arguing the petition fails to state constitutional or ADA claims and lacks allegations of personal involvement by the named officials.
The Commonwealth Court treated the objections as a demurrer, accepted well‑pled facts as true, and evaluated whether the petition could state legally cognizable claims.

Issues

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether failure to follow DOC policy (DC‑ADM 801) gives rise to §1983 relief	Rawlings: policy required mental‑health assessment and stability code consideration; DOC violated policy, causing unconstitutional punishment	DOC: violation of internal policy does not create constitutional rights; regulatory noncompliance alone is not a §1983 claim	Court: Policy breach alone cannot support §1983 relief; claim dismissed
Whether DOC officials were deliberately indifferent to serious mental‑health needs (Eighth Amendment)	Rawlings: housing him in RHU despite mental illness was deliberately indifferent and punitive beyond penological necessity	DOC: pleadings do not allege officials had the requisite culpable state of mind or that his need was objectively serious enough to preclude RHU placement	Court: Pleading lacked allegations of subjective intent or sufficiently serious need; deliberate indifference claim insufficient
Whether named officials (Wetzel, Gilmore) had requisite personal involvement	Rawlings: officials knew of harms via grievances and request slips	DOC: supervisory responsibility or after‑the‑fact grievance review is insufficient for personal liability under §1983	Court: Allegations of awareness from grievance review are conclusory; no particularized facts of personal direction or acquiescence; claim dismissed
Whether ADA claim is properly pleaded against defendants	Rawlings: alleges discrimination under ADA due to mental disability	DOC: ADA requires discrimination by a public entity; individuals are not liable under ADA; pleading lacks facts showing discrimination based on disability	Court: ADA claim fails for lack of facts showing discrimination and because defendants are individuals, not a public entity

Key Cases Cited

West v. Atkins, 487 U.S. 42 (recognizing §1983 liability requires state action and constitutional violation)
Farmer v. Brennan, 511 U.S. 825 (deliberate indifference requires culpable state of mind)
Rhodes v. Chapman, 452 U.S. 337 (Eighth Amendment and prison conditions standards)
Tindell v. Dep’t of Corr., 87 A.3d 1029 (Pa. Cmwlth.) (prison policy noncompliance does not alone establish constitutional violation)
Yount v. Dep’t of Corr., 886 A.2d 1163 (Pa. Cmwlth.) (failure to follow internal policy not a §1983 claim)
Rode v. Dellarciprete, 845 F.2d 1195 (supervisory liability requires particularized allegations of personal direction or actual knowledge and acquiescence)
Spruill v. Gillis, 372 F.3d 218 (prisoner must connect factual allegations to defendants' mental states; grievance denial alone insufficient)
Krechmar v. Dep’t of Corr., 831 A.2d 793 (Pa. Cmwlth.) (subjective element of medical deliberate indifference)
Warren v. Dep’t of Corr., 616 A.2d 140 (Pa. Cmwlth.) (plaintiff must name individually culpable defendants)
Clark v. Beard, 918 A.2d 155 (Pa. Cmwlth.) (inmate has no right to placement in particular facility or housing)
Watson v. Dep’t of Corr., 990 A.2d 164 (Pa. Cmwlth.) (ADA claims require public‑entity defendant)