Gray v. Wakefield
3:09-cv-00979
M.D. Penn.Jun 4, 2014Background
- Gray, an inmate at SCI-Huntingdon, filed 42 U.S.C. § 1981, § 1983, § 1985, § 1986 and state tort claims; Defendants are current/former DOC and SCI-Huntingdon employees; prior orders denied summary judgment on exhaustion; October 2, 2013 order denied summary judgment on some claims; Defendants moved for reconsideration asserting sovereign immunity; court granted reconsideration to bar state-law tort claims; court held defendants acted within scope of employment; nine statutory sovereign-immunity exceptions do not apply to these claims.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether state-law tort claims are barred by sovereign immunity | Gray argues immunity does not apply because acts were outside scope | Defendants contend immunity bars the claims | Sovereign immunity bars the state-law tort claims |
| Whether the Corrections Defendants acted within the scope of employment | Plaintiff contends acts were personal or outside scope | Defendants were acting as corrections officers on duty | Actions within scope; immunity applies |
| Whether any of the nine exceptions to sovereign immunity apply | Plaintiff relies on exceptions for personal reasons or unrelated purposes | No applicable exceptions | No exceptions apply; immunity remains |
Key Cases Cited
- Harsco Corp. v. Zlotnicki, 779 F.2d 906 (3d Cir. 1985) (standard for reconsideration shows limited utility)
- Max's Seafood Café v. Quineros, 176 F.3d 669 (3d Cir. 1999) (grounds for reconsideration: intervening law, new evidence, or clear error)
- North River Ins. Co. v. CIGNA Reinsurance Co., 52 F.3d 1194 (3d Cir. 1995) (grounds for reconsideration; proper use to correct error)
- Rohrbach v. AT & T Nassau Metals Corp., 902 F. Supp. 523 (M.D. Pa. 1995) (misunderstanding or error in decision; sparing use of reconsideration)
- Above the Belt, Inc. v. Mel Bohannan Roofing, Inc., 99 F.R.D. 99 (E.D. Va. 1983) (reconsideration standard; not a vehicle to relitigate issues)
- Continental Casualty Co. v. Diversified Indus. Inc., 884 F. Supp. 937 (E.D. Pa. 1995) (finality of judgments; sparing grant of reconsideration)