McFarlane v. Joseph Holly, 3:23-cv-01185

Plaintiff Robert McFarlane, an inmate at SCI-Mahanoy, was assaulted by another inmate after repeatedly alerting prison officials of threats to his safety from gang members.
McFarlane alleges that prison officials ignored his warnings, leading to his assault and severe injury, and later stole his property and legal documents during his transfer to other facilities.
The complaint raises claims under Section 1983, alleging Eighth Amendment (failure to protect), Fourteenth Amendment (due process for property loss), and First Amendment (denial of court access and retaliation) violations against various prison officials.
Defendants (major prison officials) moved to dismiss the First and Fourteenth Amendment claims for failure to state a claim and opposed McFarlane’s motion to compel discovery.
The court addressed only the sufficiency of the First and Fourteenth Amendment claims in this ruling, not the Eighth Amendment failure-to-protect issue, which remains pending.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Fourteenth Amendment Due Process (property loss)	Officials stole his property and legal documents without due process.	Plaintiff had access to adequate post-deprivation remedy (grievance process).	Dismissed; availability of a post-deprivation grievance forecloses federal due process claim.
First Amendment Access to Courts	Loss of legal paperwork denied access to courts.	Complaint fails to identify actual injury or a nonfrivolous claim lost; if claim refers to instant case, moot.	Dismissed; no showing of injury or lost claim beyond current case.
First Amendment Retaliation (cell transfer)	Retaliatory transfer for grievance filing placed him in danger.	Movements had legitimate penological objectives; no causal link to protected conduct.	Dismissed; allegations insufficient to show causation or adverse action.
Official Capacity Claims (money damages)	Sued officials in both individual and official capacities.	Eleventh Amendment bars official-capacity claims for monetary damages.	Dismissed; sovereign immunity applies.
Motion to Compel Discovery	Sought production of documents from prison counsel.	Counsel not a party; requests not served on defendants or counsel.	Denied; improper service.

Ashcroft v. Iqbal, 556 U.S. 662 (pleading standard for plausibility in federal complaints)
Bell Atl. Corp. v. Twombly, 550 U.S. 544 (complaint must include more than conclusory statements)
Parratt v. Taylor, 451 U.S. 527 (post-deprivation remedies suffice for due process when deprivation is random and unauthorized)
Hudson v. Palmer, 468 U.S. 517 (intentional property deprivation by state employees requires only post-deprivation remedy)
Bounds v. Smith, 430 U.S. 817 (inmates' right of access to courts)
Will v. Michigan Dept. of State Police, 491 U.S. 58 (states and officials in official capacities are not "persons" under § 1983 for damages)