Bracey v. Secretary Pennsylvania Department of Corrections, 686 F. App'x 130

Background

Plaintiff Corey Bracey, a Pennsylvania state prisoner, sued DOC officials and prison mental-health providers under 42 U.S.C. § 1983 challenging his housing and treatment while in RHU/SMU/SSNU and his placement on the Restricted Release List (RRL).
Bracey alleged being housed near mentally ill SSNU inmates and in an SMU continuous-camera observation cell caused a mental breakdown and denied psychiatric care; he also claimed the SMU was an "off-the-books" experimental behavior-modification unit.
Defendants (Commonwealth and medical contractors) moved for summary judgment; the Magistrate Judge recommended granting it and the District Court did so; Bracey appealed.
Record showed Bracey was placed in RHU/SMU, sometimes in a camera observation cell, later placed on RRL and transferred among institutions; medical records show repeated psychiatric contacts and a transfer to a mental-health unit for acute depression.
The court reviewed Eighth Amendment, Fourth Amendment, and procedural due process claims and found Bracey’s evidence insufficient to create genuine disputes of material fact on deliberate indifference, liberty-interest deprivation, or unlawful experimental treatment.

Issues

Issue	Plaintiff's Argument	Defendant's Argument	Held
Eighth Amendment — housing near mentally ill SSNU inmates caused harm	Housing mentally ill and non-mentally ill together caused SSNU inmates to act out and led to Bracey's mental breakdown	SSNU inmates received treatment; no proof housing caused others to act out or harmed Bracey; no deliberate indifference shown	Summary judgment for defendants — no evidence of substantial risk or causation to satisfy Farmer/§1983
SMU as ‘‘experimental’’ behavior-modification unit / cruel and unusual punishment	SMU is off-the-books experimental program forcing clandestine treatment and abusive controls	SMU policies are safety/behavior controls, not forced treatment; allegations of beatings/withheld necessities unsupported	Summary judgment for defendants — no evidence of forced experimental treatment or extreme conditions (Eighth Amendment)
Procedural due process — liberty interest in avoiding SMU or RRL placement	Placement in SMU/RRL imposed atypical and significant hardship and barred psychiatric treatment	No constitutional right to general population; conditions not atypical; periodic reviews occurred and Bracey received psychiatric care	Summary judgment for defendants — no protected liberty interest or process deficiency under Sandin and Shoats
Medical defendants — deliberate indifference to serious mental-health needs	Medical staff failed to prevent harmful housing placement and misdiagnosed/withheld appropriate treatment	Medical records show multiple evaluations, treatment, transfer to mental-health unit; differences of opinion do not show deliberate indifference	Summary judgment for medical defendants — treatment disputes/diagnostic disagreement not actionable under Estelle/Spruill

Key Cases Cited

Farmer v. Brennan, 511 U.S. 825 (prison official liable only if aware of and disregarded substantial risk)
Sandin v. Conner, 515 U.S. 472 (liberty interest inquiry: atypical and significant hardship)
Estelle v. Gamble, 429 U.S. 97 (Eighth Amendment prohibits deliberate indifference to serious medical needs)
Vitek v. Jones, 445 U.S. 480 (transfer to mental hospital triggers due process protections)
Celotex Corp. v. Catrett, 477 U.S. 317 (summary judgment burden-shifting)
Matsushita Elec. Indus. Co. v. Zenith Radio Corp., 475 U.S. 574 (standard for reasonable inferences against nonmovant)
Wilson v. Seiter, 501 U.S. 294 (Eighth Amendment conditions-of-confinement standard)
Hudson v. Palmer, 468 U.S. 517 (prison privacy rights limited by incarceration)
Spruill v. Gillis, 372 F.3d 218 (medical malpractice/disagreement not Eighth Amendment violation)
Rode v. Dellarciprete, 845 F.2d 1195 (no respondeat superior liability under § 1983)