Bennie Anderson v. Warden Berks County Prison
602 F. App'x 892
3rd Cir.2015Background
- Anderson is a Pennsylvania state prisoner serving a life sentence for murder.
- He was temporarily transferred to the Berks County Jail in July 2012 to testify in Commonwealth v. Williams and returned to SCI-Huntington in August 2012.
- Anderson alleges jail staff, including Warden Wagner and caseworker Herman, subjected him to mistreatment aimed at preventing his testimony.
- Specific allegations include nutraloaf meals, a cold cell, no blanket or daytime mattress, only three hours of lighting per day, sleep disruption, and threats by guards.
- A mistrial occurred in Commonwealth v. Williams before Anderson testified, and he was returned to his prison after less than a month in the Jail.
- Anderson filed an amended §1983 complaint in 2013 asserting Eighth Amendment and First Amendment retaliation claims; the district court granted summary judgment for the defendants.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether Anderson state an Eighth Amendment claim based on cell conditions. | Anderson contends nutraloaf, cold cell, limited light, and removal of mattress violate the Eighth Amendment. | Defendants argue the conditions do not constitute a serious deprivation. | Eighth Amendment claims affirmed for the described conditions. |
| Whether Anderson's First Amendment retaliation claim survives summary judgment. | Anderson alleges protected conduct (subpoena response) and retaliatory actions by guards. | Defendants contend he was treated like other life-sentenced inmates and not singled out. | Retaliation claim vacated and remanded for further proceedings. |
Key Cases Cited
- LeMaire v. Maass, 12 F.3d 1444 (9th Cir. 1993) (temporary nutraloaf does not deprive minimal life necessities)
- Peterkin v. Jeffes, 855 F.2d 1021 (3d Cir. 1988) (considered inadequate lighting in context of cell conditions)
- Franklin v. Lockhart, 883 F.2d 654 (8th Cir. 1989) (mattress removal and related deprivations reviewed)
- Kirleis v. Dickie, McCamey & Chilcote, P.C., 560 F.3d 156 (3d Cir. 2009) (summary judgment credibility standard; evidence must show genuine dispute)
- Corselli v. Coughlin, 842 F.2d 23 (2d Cir. 1988) (exposure to extreme cold may raise issues; defendant rulings discussed)
- Pro v. Donatucci, 81 F.3d 1283 (3d Cir. 1996) (First Amendment right to respond to a subpoena extends to prisoners)
- Rauser v. Horn, 241 F.3d 330 (3d Cir. 2001) (retaliation standard requires protected conduct, adverse action, and causal connection)
- Cornell v. Woods, 69 F.3d 1383 (8th Cir. 1995) (extension of subpoena-related protections to prisoners)
- Konits v. Valley Stream Cent. High Sch. Dist., 394 F.3d 121 (2d Cir. 2005) (First Amendment interest in responding to subpoenas)