Lee-Chima v. Hughes
1:20-cv-02349
M.D. Penn.Mar 11, 2025Background
- Plaintiff Kasheyon Lee-Chima, a state inmate, brought a §1983 civil rights suit against corrections officers at SCI Waymart, alleging Eighth and Fourteenth Amendment violations following a use-of-force incident on April 4, 2019.
- Lee-Chima claimed excessive force, failure to intervene, equal protection violations, and deliberate indifference to medical needs.
- All claims except those related to the use-of-force incident were dismissed earlier for failure to state a claim.
- Defendants sought summary judgment, arguing Lee-Chima failed to properly exhaust administrative remedies per the Prison Litigation Reform Act (PLRA).
- The case centered on whether Lee-Chima exhausted required grievance procedures and whether video evidence contradicted his claims of excessive force.
- The district court relied on video evidence and the record to assess whether a constitutional violation occurred.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Exhaustion of Administrative Remedies | Lee-Chima exhausted via grievance and reasonably identified involved officials | Not all claims/defendants were grieved as required | Not exhausted; claims vs. Van Buren/procedural default |
| Eighth Amendment Excessive Force | Defendants used unprovoked, unlawful force; caused injuries | Only necessary force; video refutes claims; de minimis force | Video and evidence show de minimis force; no violation |
| Fourteenth Amendment (Medical/Equal Protection) | Claims implied through grievance/other filings | Grievance did not mention these claims or relevant facts | Not exhausted or alleged; not properly before court |
| Relief Sought (monetary/declaratory/expungement) | Seeks damages and injunctive/declaratory relief | Only requested release from RHU in grievance | Only expungement/possibly nominal damages considered |
Key Cases Cited
- Anderson v. Liberty Lobby, Inc., 477 U.S. 242 (summary judgment standard)
- Celotex Corp. v. Catrett, 477 U.S. 317 (burden-shifting on summary judgment)
- Woodford v. Ngo, 548 U.S. 81 (proper exhaustion of administrative remedies required)
- Jones v. Bock, 549 U.S. 199 (exhaustion governed by prison grievance procedures)
- Scott v. Harris, 550 U.S. 372 (video evidence can control over contrary testimony)
- Wilkins v. Gaddy, 559 U.S. 34 (extent of injury as indication of force)
- Spruill v. Gillis, 372 F.3d 218 (consequences of failure to exhaust under PLRA)