K. Williams v. PA DOC
31 M.D. 2017
| Pa. Commw. Ct. | Sep 5, 2017Background
- Kevin Williams, an SCI-Forest inmate, petitioned the Commonwealth Court seeking mandamus relief to compel the Department of Corrections to order MRIs for his knees and shoulder, provide pain medication and permanent bottom-bunk status, return confiscated personal items, and change his housing because his cellmate smokes.
- Medical history: Williams was examined for knee pain in 2014 (x‑rays showed no significant findings) and for a clicking left shoulder in 2015 (medical staff suggested probable arthritis); he disagreed with the course of treatment and sought specialist referrals and imaging.
- Property/housing complaints: Williams alleged confiscation of personal items while in RHU and that prison grievance denials left him without a post‑deprivation remedy; he also claimed a right to a smoke‑free environment and requested single cell housing.
- Department filed preliminary objections treating the petition as a mandamus action and argued mandamus is inappropriate because medical, property, and housing decisions involve prison officials’ discretionary, professional judgment and because internal remedies suffice for property complaints.
- Court framed the action as mandamus and analyzed three groups of claims: medical treatment (Eighth Amendment deliberate indifference), ETS/smoke exposure (Eighth Amendment under Helling), and due‑process property deprivation (Fourteenth Amendment).
- Decision: Court sustained preliminary objections and dismissed the petition—finding no clear legal right to the relief requested, medical treatment disputes reflect discretionary professional judgment, insufficient factual pleading on ETS harm, and prison grievance process an adequate post‑deprivation remedy for confiscated property.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Medical care (MRI, specialists, meds) | Williams: DOC is deliberately indifferent by refusing MRIs, specialists, and pain meds | DOC: Williams received care; differences over treatment are medical judgment, not indifference | Denied — disagreement with treatment insufficient for mandamus or Eighth Amendment relief |
| Housing / smoke exposure (single cell) | Williams: right to smoke‑free environment; cellmate smokes 35–40 cigarettes/day; needs single cell | DOC: No right to choose cell; housing is discretionary and courts should defer to prison administration | Denied — pleadings lack facts showing unreasonably high ETS exposure; DOC discretion controls |
| Return of confiscated personal items | Williams: deprivation of property without adequate remedy | DOC: Prisons may restrict inmate property; internal grievance procedures are available | Denied — prison grievance system is an adequate post‑deprivation remedy; no clear right to items |
| Nature of action (mandamus appropriateness) | Williams sought specific actions by DOC (imaging, meds, housing, return of property) | DOC: mandamus improper because requests seek to control discretionary, professional judgments | Court treated petition as mandamus and held mandamus inappropriate where relief would override discretionary judgments |
Key Cases Cited
- Kretchmar v. Department of Corrections, 831 A.2d 793 (Pa. Cmwlth. 2003) (mandamus requires a clear legal right and cannot direct discretionary medical judgment)
- Estelle v. Gamble, 429 U.S. 97 (1976) (Eighth Amendment deliberate indifference standard for prison medical care)
- Farmer v. Brennan, 511 U.S. 825 (1994) (two‑prong deliberate indifference test: objective harm and subjective knowledge)
- Helling v. McKinney, 509 U.S. 25 (1993) (ETS exposure can constitute Eighth Amendment violation if exposure is unreasonably high)
- Bell v. Wolfish, 441 U.S. 520 (1979) (deference to prison administrators and limits on prisoners’ rights under security concerns)
- Sandin v. Conner, 515 U.S. 472 (1995) (courts should defer to prison administrators in running prisons)
- Tillman v. Lebanon County Correctional Facility, 221 F.3d 410 (3d Cir. 2000) (prison grievance systems can provide adequate post‑deprivation remedies)
- Small v. Horn, 722 A.2d 664 (Pa. 1998) (reasonable prison regulations limiting inmate property do not violate due process)
- Pennsylvania Dental Association v. Insurance Department, 516 A.2d 647 (Pa. 1986) (mandamus cannot be used to control exercise of discretion by public officials)
- Buehl v. Beard, 54 A.3d 412 (Pa. Cmwlth. 2012) (elements required for mandamus relief)