Joseph Aruanno v. Jon Corzine
687 F. App'x 226
| 3rd Cir. | 2017Background
- Plaintiff Joseph Aruanno is civilly confined at New Jersey’s Special Treatment Unit under the SVPA and brought a § 1983 suit challenging various conditions and practices at the STU.
- Aruanno’s 2007 complaint was largely consolidated into the Alves class-action settlement; the district court later deconsolidated and reinstated non-settled claims (facilities, living conditions, security, searches, property).
- After discovery (including Aruanno’s deposition), defendants moved for summary judgment; Aruanno filed an inadequate counter-motion and did not submit a statement of material facts.
- The district court treated Aruanno’s deposition testimony as his statement of facts, limited claims to events within the statute-of-limitations period, and granted summary judgment for defendants on all remaining claims.
- On appeal, the Third Circuit reviewed de novo and affirmed, holding Aruanno failed to show supervisory liability, unconstitutional conditions or punishment, unequal treatment without a rational basis, or constitutional injury from denial of work/startup activities.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Supervisory liability for alleged abuses | Supervisors at STU are responsible for name-calling, searches, verbal abuse, excessive force and failure to train/supervise | Defendants lacked personal involvement or prior knowledge; no policy or deliberate indifference shown | Affirmed — no supervisory liability; plaintiff failed to show personal involvement, policy causation, or deliberate indifference |
| Conditions of confinement / punitive treatment (MAP) | STU conditions and MAP restrictions are punitive and violate due process / liberty interests | MAP and other restrictions are reasonably related to security and treatment and not "punishment" in constitutional sense | Affirmed — conditions do not violate due process; MAP serves legitimate objectives and is not constitutionally punitive |
| Equal protection (comparison to civilly committed mental patients) | SVP residents are treated differently (e.g., fewer privileges); this is unequal treatment compared to other civil commitments | Sexually violent predators are not similarly situated to ordinary civilly committed mental patients; there are rational bases for different treatment | Affirmed — rational basis exists for different treatment; equal protection claim fails |
| Denial of job / entrepreneurial activity for refusal of treatment | Denying job or business startup because resident refuses treatment infringes rights | Denial is related to treatment and security goals; confinement may lawfully condition privileges on treatment participation | Affirmed — denial of job/startup does not amount to a constitutional violation |
Key Cases Cited
- Burns v. Pennsylvania Department of Corrections, 642 F.3d 163 (3d Cir. 2011) (standard for summary judgment review in § 1983 cases)
- Parkell v. Danberg, 833 F.3d 313 (3d Cir. 2016) (elements for supervisory liability in § 1983 suits)
- Youngberg v. Romeo, 457 U.S. 307 (U.S. 1982) (liberty interests of civilly committed persons and conditions of confinement)
- Bell v. Wolfish, 441 U.S. 520 (U.S. 1979) (pretrial detainee cannot be punished; restrictions must be related to legitimate objectives)
- Kingsley v. Hendrickson, 135 S. Ct. 2466 (U.S. 2015) (objective evidence standard for punitive conditions)
- McKune v. Lile, 536 U.S. 24 (U.S. 2002) (conditioning privileges on participation in treatment programs is permissible)
- Renchenski v. Williams, 622 F.3d 315 (3d Cir. 2010) (equal protection requires disparate treatment of similarly situated persons)
- City of Canton v. Harris, 489 U.S. 378 (U.S. 1989) (failure-to-train claim requires deliberate indifference)
- Hudson v. Palmer, 468 U.S. 517 (U.S. 1984) (post-deprivation state remedies can preclude § 1983 takings claims)
- Dique v. New Jersey State Police, 603 F.3d 181 (3d Cir. 2010) (statute of limitations for § 1983 claims in New Jersey)