GROHS v. RAUPP, 1:25-cv-00637

Plaintiffs Steven Grohs and Joseph Walls are civilly committed residents at New Jersey’s Special Treatment Unit pursuant to the Sexually Violent Predator Act.
They filed pro se a civil rights complaint under 42 U.S.C. § 1983, alleging violations of the Eighth and Fourteenth Amendments due to inadequate living conditions.
Specific complaints include lack of hot water for showers, nonfunctional dryers in laundry facilities, and insufficient television reception.
Defendants, Crystal Raupp and P. McGill, administrators at the Unit, were repeatedly notified about these facility deficiencies.
Plaintiffs allege these conditions worsened existing medical problems.
The court conducted an initial screening under 28 U.S.C. § 1915(e)(2) due to plaintiffs’ in forma pauperis status.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Conditions violate Due Process (showers/laundry)	Lack of hot water and dryers harm health and hygiene	Facility does not violate minimum constitutional standards	Allowed claim to proceed; plausibly states a claim
Inadequate TV reception as constitutional violation	Poor TV access is a deprivation	No right to TV under the Constitution	Dismissed; no constitutional claim stated

Ashcroft v. Iqbal, 556 U.S. 662 (2009) (pleading requirements for facial plausibility in civil complaints)
Youngberg v. Romeo, 457 U.S. 307 (1982) (minimum constitutional standards for civilly committed individuals)
Bell Atl. Corp. v. Twombly, 550 U.S. 544 (2007) (standard for pleading sufficient facts in civil complaints)
Erickson v. Pardus, 551 U.S. 89 (2007) (pro se complaints should be held to less stringent standards)
Fair Wind Sailing, Inc. v. Dempster, 764 F.3d 303 (3d Cir. 2014) (elaborating on pleading standards as set out in Iqbal and Twombly)
Fowler v. UPMC Shadyside, 578 F.3d 203 (3d Cir. 2009) (explains plausibility standard for complaints)