K. Williams v. PA DOC
31 M.D. 2017
Pa. Commw. Ct.Sep 5, 2017Background
- Petitioner Kevin Williams, an inmate at SCI‑Forest, sought a writ of mandamus compelling the Department of Corrections to order MRIs for his knees and shoulder, provide pain medication and bottom‑bunk status, return confiscated personal property, and change his cell assignment to avoid secondhand smoke.
- Medical visits: Williams was examined for knee pain (x‑rays showed no significant findings) and left shoulder clicking (medical staff suspected arthritis); he sought specialist care and MRIs which were denied and grieved administratively.
- Housing/ETS: Williams contends his cellmate smokes heavily and that he has a right to a smoke‑free environment or a single cell; his housing‑related grievances were denied.
- Property: After placement in RHU, several personal items were confiscated; Williams used the prison grievance system but was denied return of the items and alleges due process deprivation.
- Procedural posture: Williams filed a petition for review in this Court (treated as a mandamus action). The Department filed preliminary objections (demurrer). The Court sustained the objections and dismissed the petition.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Medical treatment (MRIs, meds, bottom bunk) | Williams: denial of MRIs/meds and refusal to send to specialists is deliberate indifference to serious medical needs. | DOC: medical decisions and treatment priorities are discretionary and reflect professional judgment; mandamus cannot dictate treatment. | Court: Denied — inmate received medical attention; disagreement over treatment does not show deliberate indifference or a clear right to mandate specific care. |
| Housing / secondhand smoke | Williams: has a right to a smoke‑free environment; requests single cell to avoid ETS. | DOC: No constitutional right to single cell; housing assignments are discretionary and entitled to deference. | Court: Denied — Williams pleaded no facts showing exposure to unreasonably high ETS levels or health harm per Helling; no clear right to mandamus. |
| Confiscated personal property / due process | Williams: deprivation of property without adequate post‑deprivation remedy. | DOC: Prisons may limit inmate property; the internal grievance process is an adequate post‑deprivation remedy. | Court: Denied — grievance system is an adequate remedy; no clear right to have items returned via mandamus. |
| Other allegations (mail, legal papers) | Williams: alleges mail tampering and confiscation of legal paperwork. | DOC: Not addressed in detail. | Court: Dismissed — claims not sufficiently pleaded for evaluation. |
Key Cases Cited
- Kretchmar v. Department of Corrections, 831 A.2d 793 (Pa. Cmwlth. 2003) (mandamus standard for compelling prison medical treatment)
- Buehl v. Beard, 54 A.3d 412 (Pa. Cmwlth. 2012) (elements and limits of mandamus relief)
- Estelle v. Gamble, 429 U.S. 97 (1976) (Eighth Amendment requires adequate medical care; deliberate indifference standard)
- Farmer v. Brennan, 511 U.S. 825 (1994) (subjective and objective elements of deliberate indifference)
- Pennsylvania Dental Association v. Insurance Department, 516 A.2d 647 (Pa. 1986) (mandamus cannot control exercise of official discretion)
- Helling v. McKinney, 509 U.S. 25 (1993) (Eighth Amendment claim for environmental tobacco smoke requires proof of unreasonable exposure and risk)
- Tillman v. Lebanon County Correctional Facility, 221 F.3d 410 (3d Cir. 2000) (prison grievance systems can be adequate post‑deprivation remedies)
- Small v. Horn, 722 A.2d 664 (Pa. 1998) (reasonable prison regulations may limit inmate property rights)
- Bell v. Wolfish, 441 U.S. 520 (1979) (deference to prison administration on security and regimen decisions)