JULIAN v. BEARD, 2:11-cv-00131

Julian, an inmate at SCI-Mercer, alleges §1983 violations against multiple DOC officials.
In May 2009 he fell from a top bunk due to a bottom-bunk order allegedly not followed.
Staff allegedly lacked training on a DOCNet system and failed to verify bottom-bunk status.
Grievances and internal appeals followed, resulting in some corrective actions and later reversals.
Plaintiff contends retaliation and unsafe housing assignments affected by staff decisions.
The court grants in part a partial motion to dismiss, and dismisses official-capacity claims as barred by the Eleventh Amendment.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether Beard, Zwierzyna, and Harlow meet personal liability.	Beard/ Zwierzyna/ Harlow caused or condoned harm through their roles.	No personal directions or knowledge established; no supervisory liability.	Claims against Beard, Zwierzyna, and Harlow in their individual capacities dismissed.
Whether official-capacity claims are barred by the Eleventh Amendment.	Official-capacity claims should proceed against state actors.	Eleventh Amendment immunity blocks official-capacity claims; state cannot be sued in federal court.	Official-capacity claims dismissed due to Eleventh Amendment immunity.
Whether the complaint adequately asserts supervisory-liability theory under Third Circuit standards.	Supervisors failed to prevent harm or respond to patterns of injuries.	Plaintiff fails to identify specific supervisory practices or known patterns.	Beards, Zwierzyna, and Harlow not liable under supervisory liability; standard unmet.
Whether the grievance process evidence creates personal involvement for Harlow.	Harlow reviewed/answered grievances constituting involvement.	Response to grievances does not establish personal involvement.	Grievance responses do not establish personal involvement; no §1983 claim against Harlow.

Evancho v. Fisher, 423 F.3d 347 (3d Cir. 2005) (adequacy of complaint requires conduct, time, place, and responsible persons)
Sample v. Diecks, 885 F.2d 1099 (3d Cir.1989) (requires identification of a specific supervisory practice; four-part test for supervisory liability)
Beers-Capitol v. Beers-Capitol, 256 F.3d 120 (3d Cir.2001) (pattern of injuries and inaction can show supervisor indifference)
Farmer v. Brennan, 511 U.S. 825 (U.S. 1994) (plaintiff must show the supervisor knew or ignored an excessive risk)
Gay v. Petsock, 917 F.2d 768 (3d Cir.1990) (supervisory liability requires knowledge and acquiescence)
Rizzo v. Goode, 423 U.S. 362 (U.S. 1976) (personal involvement required; cannot rely on respondeat superior)
Chinchello v. Fenton, 805 F.2d 126 (3d Cir.1986) (personal involvement shown by direction or knowledge and acquiescence)
Will v. Michigan Dept. of State Police, 491 U.S. 58 (U.S. 1989) (§1983 does not abrogate state sovereign immunity)
Pennhurst State School & Hospital v. Halderman, 465 U.S. 89 (U.S. 1984) (sovereign immunity limits federal-court actions against states)
Estelle v. Gamble, 429 U.S. 97 (U.S. 1976) (standard for evaluating constitutional claims in §1983 actions)