La-Qun Williams v. Louis Folino
664 F. App'x 144
3rd Cir.2016Background
- Plaintiff La-Qun Rasheed Williams, a prisoner at SCI Greene proceeding pro se, sued prison officials under 42 U.S.C. § 1983 (retaliation, Eighth Amendment medical claims, excessive force, conditions, due process) and state-law negligence; case removed to federal court and assigned to a Magistrate Judge.
- The Magistrate Judge dismissed excessive force, unconstitutional confinement, and due process claims on a Rule 12(b)(6) basis, but permitted retaliation and deliberate-indifference medical claims to proceed; defendants then moved for summary judgment on the remaining federal claims.
- At summary judgment the Magistrate Judge granted defendants judgment on the federal claims (deliberate indifference and various retaliation theories) and remanded the remaining state-law negligence claim to Pennsylvania state court; Williams timely appealed.
- Key factual dispute concerned whether Williams submitted sick-call/request slips and grievances in late 2013 reporting recurrent seizures and whether non-medical staff deliberately ignored or obstructed his access to medical care; the record included sick-call logs, submission records, grievances, and video of an escort to the shower.
- The Magistrate Judge found documentary evidence showed Williams was seen by medical staff during the relevant period and that prison records contradicted his asserted sick-call submissions; video showed no excessive force; misconduct finding was supported by a written statement; library records showed he received entitled access.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Deliberate indifference to serious medical needs | Williams: he suffered recurring seizures and submitted sick-call slips, requests, and a grievance that were ignored, causing unconstitutional delay/denial of care | Defendants: records show he was seen by medical staff; disputed sick-call slips not evidenced on logs; non-medical staff had no reason to know of mistreatment by medical providers | Summary judgment for defendants — no genuine dispute that non-medical defendants were deliberately indifferent |
| Retaliation via excessive force during escort | Williams: Officer Sumey used excessive force in retaliation for filing grievances | Defendants: video shows only a routine escort, no excessive force | Summary judgment for defendants — video does not create a triable issue |
| Retaliation via misconduct charge (lying) | Williams: misconduct was false and issued in retaliation for grievance | Defendants: misconduct supported by written statement; disciplining false grievance furthers penological interests | Summary judgment for defendants — misconduct was legitimate and not retaliatory |
| Retaliation via denial of law-library access | Williams: he was denied adequate library access and unable to bring materials while restrained, as retaliation | Defendants: records show Williams received entitled library time (at least two hours/week); no evidence he was entitled to more | Summary judgment for defendants — plaintiff failed to show adverse action or causal link |
| State-law negligence claims | Williams: negligence claims remained as pendent/state claims | Defendants: federal claims resolved, so retention of supplemental jurisdiction inappropriate | Remanded to Pennsylvania state court under §1367(c)(3) — district court declined to retain pendent state claims |
Key Cases Cited
- Estelle v. Gamble, 429 U.S. 97 (Eighth Amendment deliberate indifference to serious medical needs)
- Spruill v. Gillis, 372 F.3d 218 (3d Cir. 2004) (non-medical officials not liable absent reason to believe medical staff are mistreating inmate)
- Monmouth County Correctional Inst. Inmates v. Lanzaro, 834 F.2d 326 (3d Cir. 1987) (deliberate indifference includes burdensome procedures causing denials/delays)
- Durmer v. O’Carroll, 991 F.2d 64 (3d Cir. 1993) (non-physician defendants not liable where prison doctor is treating plaintiff)
- Blunt v. Lower Merion Sch. Dist., 767 F.3d 247 (3d Cir. 2014) (summary judgment standard; mere allegations insufficient)
- Lauren W. v. DeFlaminis, 480 F.3d 259 (3d Cir. 2007) (plaintiff must establish essential elements to avoid summary judgment)
- Rauser v. Horn, 241 F.3d 330 (3d Cir. 2001) (elements of prisoner retaliation claim)
- Watson v. Rozum, 834 F.3d 417 (3d Cir. 2016) ("quantum of evidence" standard for prison misconduct legitimacy)
- Dyson v. Kocik, 689 F.2d 466 (3d Cir. 1982) (misconduct findings require meaningful written statement of evidence)
- Kossler v. Crisanti, 564 F.3d 181 (3d Cir. 2009) (appellate review may affirm on any ground supported by record)
- Carnegie–Mellon Univ. v. Cohill, 484 U.S. 343 (district court discretion to remand pendent state claims)
- Wilkins v. Gaddy, 559 U.S. 34 (Eighth Amendment excessive force requires more than de minimis force)
- Massey v. Helman, 259 F.3d 641 (7th Cir. 2001) (handling of grievances does not give rise to due process claim)
- Lebanon County Correctional Facility v. Tillman, 221 F.3d 410 (3d Cir. 2000) (discusses Eighth Amendment scienter requirement)