Goode v. Warden Curran Fromhold Correctional Facility
669 F. App'x 622
| 3rd Cir. | 2016Background
- Ronald Goode, a pretrial detainee at Curran Fromhold, sued the Warden under 42 U.S.C. § 1983 alleging denial of Muslim religious services and styled the suit as a class action.
- No class was ever certified; Goode sought injunctive relief to use facilities for religious practice and did not expressly pray for damages (though he alleged public, mental, and emotional injuries elsewhere).
- The District Court dismissed Goode’s complaint under Fed. R. Civ. P. 12(b)(6) for failure to state a claim.
- After the appeal was filed, Goode pleaded guilty on state charges, received a state sentence, and was transferred from Curran Fromhold to SCI-Graterford.
- The Third Circuit considered whether Goode’s transfer and the lack of class certification rendered his claims moot and whether any damages claim could survive under the Prison Litigation Reform Act.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Mootness of injunctive relief | Goode sought an injunction to use Curran Fromhold facilities for religious practice. | Transfer from Curran Fromhold moots request for injunctive relief because Goode is no longer housed there. | Case is moot; no live controversy; appeal dismissed. |
| Class action viability | Styled as class action; relief would benefit class. | Named plaintiff’s claim became moot before class certification, so action must be dismissed. | Dismissal required because no class was certified before mootness. |
| Damages recoverable for emotional injury | Alleged public, mental, and emotional injuries might imply damages. | Even if damages sought, PLRA bars recovery for mental or emotional injury absent physical harm. | Damages unavailable under 42 U.S.C. § 1997e(e); affirm dismissal on that ground too. |
Key Cases Cited
- Flast v. Cohen, 392 U.S. 83 (1968) (Article III case-or-controversy requirement limits federal jurisdiction)
- County of Los Angeles v. Davis, 440 U.S. 625 (1979) (mootness divests federal courts of jurisdiction when issues are no longer live)
- Surrick v. Killion, 449 F.3d 520 (3d Cir. 2006) (change in circumstances that forecloses meaningful relief renders a case moot)
- Brown v. Philadelphia Housing Authority, 350 F.3d 338 (3d Cir. 2003) (named plaintiffs’ claims that become moot before class certification require dismissal)
- Sosna v. Iowa, 419 U.S. 393 (1975) (once a class is certified, mooting a representative’s claim does not moot the class action)
- Weaver v. Wilcox, 650 F.2d 22 (3d Cir. 1981) (transfer of inmate typically moots injunctive relief directed at prior facility)