MCGILL v. LANIGAN, 2:13-cv-07386

McGill, a New Jersey state prisoner, was diagnosed with Bell’s palsy on Dec. 4, 2011 while housed in the “2‑up dormitory” at East Jersey State Prison and treated with medications and eye drops.
McGill alleges extensive mold, fungal growth, leaking roof with bird feces contamination, and other unsanitary conditions in the 2‑up dormitory and ties his Bell’s palsy (and similar cases among inmates/staff) to those conditions.
McGill sued Commissioner Gary Lanigan under 42 U.S.C. § 1983 raising an Eighth Amendment conditions‑of‑confinement claim; Lanigan moved for summary judgment and McGill cross‑moved.
Lanigan argued (inter alia) McGill failed to exhaust administrative remedies under the PLRA and, dispositively, failed to produce evidence establishing causation between dormitory conditions and Bell’s palsy; Lanigan also raised lack of personal involvement and qualified immunity defenses.
The district court granted Lanigan’s motion on causation grounds, concluding McGill offered no expert or other competent evidence linking the alleged conditions to his Bell’s palsy; the court did not decide exhaustion due to the dispositive causation ruling.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Exhaustion under PLRA	McGill says he filed grievances/Notice of Tort Claim and that officials lost/redirected complaints, making remedies unavailable	Lanigan says McGill filed no IRFs related to Bell’s palsy at the relevant prisons and thus did not exhaust	Court declined to decide exhaustion because other grounds were dispositive
Causation for §1983 Eighth Amendment claim	McGill argues prison conditions caused his Bell’s palsy; points to other inmates/staff with similar diagnoses	Lanigan argues McGill has no evidence (no expert) linking mold/feces/asbestos to Bell’s palsy and McGill admitted he does not know the cause	Court held McGill failed to show proximate causation; summary judgment for defendant granted
Deliberate indifference / personal involvement	McGill contends Lanigan toured the dormitory and knew of conditions and did nothing	Lanigan disputes personal involvement and argues no deliberate indifference shown	Court did not reach these issues because causation was dispositive
Requirement of expert proof for medical causation	McGill relies on lay testimony and occurrence of others with Bell’s palsy	Lanigan asserts expert testimony is required to establish that specific prison conditions caused Bell’s palsy	Court agreed that absent expert evidence, no reasonable jury could infer causation; lay conjecture insufficient

Anderson v. Liberty Lobby, 477 U.S. 242 (summary judgment standard and materiality)
Celotex Corp. v. Catrett, 477 U.S. 317 (shifting burdens on summary judgment)
Farmer v. Brennan, 511 U.S. 825 (Eighth Amendment deliberate indifference framework)
Ross v. Blake, 136 S. Ct. 1850 (PLRA exhaustion; when remedies are "unavailable")
Jones v. Bock, 549 U.S. 199 (exhaustion is an affirmative defense under the PLRA)
Woodford v. Ngo, 548 U.S. 81 (proper exhaustion requires compliance with procedural rules)
Porter v. Nussle, 534 U.S. 516 (PLRA exhaustion applies to all inmate suits about prison life)
Wilson v. Seiter, 501 U.S. 294 (standards for conditions‑of‑confinement claims)
Hudson v. Palmer, 468 U.S. 517 (prison officials’ duty to ensure inmate safety)
Graham v. Connor, 490 U.S. 386 (§ 1983 as a vehicle for constitutional claims)