Joshua Payne v. K. Ducan
692 F. App'x 680
| 3rd Cir. | 2017Background
- Plaintiff Joshua Payne, a Pennsylvania inmate, sued six SCI Camp Hill employees under 42 U.S.C. § 1983 alleging retaliation, destruction of legal and religious materials, denial of property paperwork, conspiracy, and equal protection violations following a March 2013 cell search.
- Payne alleged Duncan and Ziegler searched his cell and discarded materials; McElwain and Settle refused to act on his reports; Whalen and Bell were implicated in grievance-related conspiracies.
- Payne filed an initial prison grievance in March 2013 and a subsequent grievance; the initial grievance named only Whalen and was addressed to Bell. Appeals failed to identify the other named defendants or raise several constitutional claims.
- Defendants moved to dismiss or for summary judgment; the District Court granted summary judgment for defendants. Payne appealed pro se and in forma pauperis.
- The Third Circuit reviewed the grant of summary judgment de novo and concluded Payne failed to properly exhaust administrative remedies as required by 42 U.S.C. § 1997e(a), warranting summary affirmance.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether Payne exhausted administrative remedies for claims against each defendant | Payne contends he filed grievances and appealed, raising the relevant claims against prison staff | Defendants argue Payne failed to identify most defendants or raise the constitutional claims in the grievance process | Held: Payne did not properly exhaust because grievances named only Whalen and did not present the other defendants or many claimed constitutional violations |
| Whether Payne exhausted remedies as to access-to-courts, conspiracy, due process, Eighth Amendment, and equal protection claims | Payne asserts these claims were raised through his grievances and appeals | Defendants argue the grievances and appeals did not assert these specific claims or identify necessary facts/defendants | Held: Not exhausted; claims were not presented in administrative process |
| Whether summary judgment was appropriate based on exhaustion failure | Payne argues merits should be reached despite procedural defects | Defendants maintain exhaustion is a jurisdictional/mandatory prerequisite barring suit | Held: Summary judgment for defendants affirmed because no genuine dispute of material fact on exhaustion |
| Whether any disputed material facts preclude summary judgment | Payne implies factual disputes about property destruction and conspiracy | Defendants point to absence of administrative exhaustion as dispositive procedural bar | Held: No genuine dispute on exhaustion; Defendants entitled to judgment as a matter of law |
Key Cases Cited
- Gallo v. City of Philadelphia, 161 F.3d 217 (3d Cir. 1998) (standard of review for summary judgment in this circuit)
- Coolspring Stone Supply, Inc. v. Am. States Life Ins. Co., 10 F.3d 144 (3d Cir. 1993) (view facts in light most favorable to nonmoving party)
- Celotex Corp. v. Catrett, 477 U.S. 317 (U.S. 1986) (summary judgment standards and burdens)
- Woodford v. Ngo, 548 U.S. 81 (U.S. 2006) (proper exhaustion requirement under the PLRA)
- Spruill v. Gillis, 372 F.3d 218 (3d Cir. 2004) (prison grievance must identify relevant facts and defendants to satisfy exhaustion)