Guillermo Ruiz v. United States, 664 F. App'x 130

Guillermo Ruiz, a federal prisoner, sued the United States under the Federal Tort Claims Act for injuries he alleged occurred while restrained and for being forced to accept particular cellmates while at USP–Lewisburg.
Ruiz claimed he was removed from his cell, placed in ambulatory restraints applied too tightly for a period he initially alleged was 48 hours (record showed 21 hours), suffered lacerations, chest pain, breathing difficulty, fainting, and was denied medical care, food, and water. He also alleged being assigned an HIV-positive cellmate while still having open wounds.
The Government moved for dismissal/summary judgment; the District Court treated it as summary judgment and granted it.
The District Court dismissed the cellmate claims under the FTCA’s discretionary function exception, barred the misconduct-related claim under Heck’s favorable-termination rule, and found no genuine dispute as to food/water deprivation or inadequate medical care.
Ruiz appealed pro se; the Third Circuit reviewed the grant of summary judgment de novo and summarily affirmed, finding no substantial question presented.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether cellmate assignments are actionable under the FTCA	Ruiz: forcing him to accept a gang member and later an HIV-positive cellmate violated duty of care	U.S.: assignments involve discretionary judgment by BOP and fall within FTCA discretionary function exception	Dismissed — discretionary function exception applies
Whether misconduct/disciplinary finding supports FTCA relief for loss of good-conduct time	Ruiz: disciplinary process and sanctions caused harm for which FTCA relief is available	U.S.: success would imply invalidity of disciplinary sanction; Heck bars suit absent favorable termination	Dismissed — Heck favorable-termination rule bars claim
Whether denial of food and water while restrained rose to constitutional/FTCA liability	Ruiz: was denied adequate food and water during restraints	U.S.: records show food and water were available and consumed; no substantial deprivation	Dismissed — no genuine dispute of material fact; no substantial deprivation
Whether medical care was constitutionally inadequate (deliberate indifference)	Ruiz: suffered lacerations, chest pain, fainting and was denied adequate medical care	U.S.: video and records show regular medical checks, no complaints or signs of injury; basic care provided	Dismissed — no deliberate indifference; summary judgment appropriate

United States v. Muniz, 374 U.S. 150 (prisoner may invoke FTCA for injuries in confinement)
Gaubert v. United States, 499 U.S. 315 (discretionary function exception analysis)
Mitchell v. United States, 225 F.3d 361 (two-prong test for discretionary function in Third Circuit)
Bell v. Wolfish, 441 U.S. 520 (deference to prison administrators for security and discipline)
Heck v. Humphrey, 512 U.S. 477 (favorable-termination rule bars civil claims that imply invalidity of confinement)
Estelle v. Gamble, 429 U.S. 97 (standard for deliberate indifference to serious medical needs)
Rouse v. Plantier, 182 F.3d 192 (Third Circuit discussion of prison medical care standards)
Erlin v. United States, 364 F.3d 1127 (FTCA claims related to imprisonment accrue only after invalidation of confinement)