MARCHETTI v. DIRENZIO, 2:15-cv-04676

Background

Plaintiff John Marchetti, diagnosed with PTSD from prior abuse, was incarcerated in Pennsylvania and prescribed Celexa and seen by mental-health staff while at SCI Laurel Highlands.
On March 27–28, 2014 Marchetti learned a detainer would extend his confinement; he was placed in the Restricted Housing Unit (RHU) and appeared before a three-member Program Review Committee that included defendants Pleacher and DiBridge.
Marchetti told the PRC that RHU conditions triggered and worsened his PTSD and requested relocation; mental-health staff continued to treat him and maintained his Celexa prescription while declining his request for a dosage increase.
On April 3, 2014 Marchetti was transferred to Delaware County custody and later to George W. Hill, where Officer Raymond allegedly assigned him to a shared cell with an unhygienic cellmate despite a claimed medical directive to house him alone.
Marchetti sued under 42 U.S.C. § 1983 asserting Eighth Amendment claims (deliberate indifference / conditions of confinement) against Pleacher, DiBridge, and Raymond; Pleacher/DiBridge and Raymond moved for summary judgment.
The court granted both motions, dismissing all claims against Pleacher, DiBridge, and Raymond for failure to show deliberate indifference or deprivation of an identifiable human need.

Issues

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether Pleacher/DiBridge were deliberately indifferent to Marchetti's serious medical need (PTSD) by keeping him in RHU	Marchetti: RHU conditions triggered and worsened PTSD; PRC members could have moved him but did not	Pleacher/DiBridge: they were administrators, not medical providers; medical staff treated Marchetti and made housing/medical decisions	Court: Dismissed — no personal involvement or interference with medical care; plaintiff received treatment and disagreement/dissatisfaction with care ≠ deliberate indifference
Whether RHU conditions constituted an Eighth Amendment conditions-of-confinement violation	Marchetti: RHU deprivation aggravated PTSD and caused severe emotional distress	Defendants: conditions were typical RHU restrictions and did not deprive basic human needs	Court: Dismissed — conditions alleged do not show denial of "minimal civilized measures" or substantial risk of serious harm
Whether Officer Raymond violated Eighth Amendment by placing Marchetti with an unhygienic cellmate contrary to medical directive	Marchetti: Raymond knowingly assigned him to a cell with a reportedly infectious, unhygienic cellmate, violating a housing directive to be housed alone	Raymond: lacked supervisory authority to change assignments and had no recollection or knowledge of a housing directive; cell was empty when escorted	Court: Dismissed — plaintiff failed to show Raymond usurped authority or had knowledge of a risk sufficient for deliberate indifference
Whether summary judgment was appropriate given disputed facts	Marchetti: factual disputes (e.g., existence/communication of medical housing slip) create triable issues	Defendants: record shows treatment, lack of personal involvement, and institutional protocols limiting defendants' roles	Court: Granted summary judgment for defendants — even viewing facts favorably to plaintiff, no reasonable jury could find constitutional violation

Key Cases Cited

Estelle v. Gamble, 429 U.S. 97 (deliberate indifference to serious medical needs violates Eighth Amendment)
Farmer v. Brennan, 511 U.S. 825 (definition of serious medical need and deliberate indifference standard)
Durmer v. O'Carroll, 991 F.2d 64 (non-physician prison officials not liable when medical staff treat prisoner)
Spruill v. Gillis, 372 F.3d 218 (prison administrators may rely on medical staff; need personal involvement)
Celotex Corp. v. Catrett, 477 U.S. 317 (party moving for summary judgment may show absence of evidence for essential element)
Wilson v. Seiter, 501 U.S. 294 (conditions-of-confinement claims require deprivation of an identifiable human need and deliberate indifference)