Nelson Ryder v. Janet Bartholomew, 15-1851

Background

Nelson Ryder, a Pennsylvania inmate, sued prison officials, Prison Health Services (PHS), and several PHS physician assistants asserting Eighth, First, and Fourteenth Amendment claims plus state professional negligence and Monell claims arising from termination from a prison job, medical care, and grievance-related retaliation.
Ryder filed multiple grievances (notably Grievance No. 456907 filed April 17, 2013) and initiated suit June 2, 2013. Defendants moved to dismiss or for summary judgment; discovery was stayed pending resolution of motions.
Commonwealth Defendants missed their initial answer deadline, sought relief under Fed. R. Civ. P. 6(b)(1)(B), and the magistrate and district courts allowed the late filing; Ryder’s motion for default was denied/mooted.
The District Court granted summary judgment/dismissal for PHS and Commonwealth Defendants; the magistrate had recommended dismissal for all but the Medical Defendants initially, then renewed that recommendation after remand.
On appeal, the Third Circuit reviewed: (1) the excusable-neglect ruling for the Commonwealth Defendants’ late filing; (2) whether Ryder exhausted administrative remedies under the PLRA (42 U.S.C. § 1997e(a)), focusing on Grievance No. 456907; and (3) whether the District Court prematurely granted PHS summary judgment on a Monell privacy-related claim without allowing discovery under Rule 56(d).

Issues

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether court abused discretion in allowing Commonwealth Defs. to file late (excusable neglect) and denying default	Ryder argued service was proper and default should have been entered when no timely answer was filed	Commonwealth Defs. argued delay was excusable neglect under Pioneer factors and sought nunc pro tunc relief under Rule 6(b)(1)(B)	Affirmed: court did not abuse discretion; Pioneer factors supported excusable neglect and default denial/mooting was appropriate
Whether Ryder failed to exhaust PLRA remedies for post-suit grievances	Ryder argued some claims were timely exhausted or remedies were unavailable due to prison conduct	Commonwealth Defs. argued non-exhaustion bars post-suit claims and dismissal is required	Affirmed in part: summary judgment proper as to claims grounded in grievances filed after the suit (non-exhausted)
Whether Grievance No. 456907 (pre-suit, consolidated grievance) was exhausted or remedies were unavailable	Ryder argued remedies were "unavailable" because the prison delayed, misled him, and failed to provide timely written decision	Commonwealth Defs. argued Ryder misinterprets grievance policy and remedies remained available	Reversed/vacated as to this issue: material factual dispute exists whether remedies were unavailable (prison missed deadlines and communications), so summary judgment inappropriate; remand required
Whether District Court properly granted PHS summary judgment on Monell privacy claim without permitting discovery	Ryder argued he was denied opportunity to conduct discovery under Rule 56(d) and had pleaded a plausible Fourteenth Amendment privacy claim	PHS argued it was not the DOC contractor during the period and thus not liable; court relied on submitted documents to dismiss	Reversed/vacated as to PHS: court prematurely granted summary judgment without allowing discovery; remand for further proceedings and discovery on privacy-related Monell claim

Key Cases Cited

Pioneer Inv. Servs. Co. v. Brunswick Assocs., 507 U.S. 380 (excusable neglect factors for late filings)
Porter v. Nussle, 534 U.S. 516 (prison-condition suits subject to PLRA exhaustion)
Woodford v. Ngo, 548 U.S. 81 (exhaustion must comply with applicable procedural rules)
Ross v. Blake, 136 S. Ct. 1850 (remedies are not required if they are unavailable)
Celotex Corp. v. Catrett, 477 U.S. 317 (summary judgment burden allocation)
Liberty Lobby, Inc. v. Anderson, 477 U.S. 242 (summary judgment standard; more than a scintilla required)
Monell v. Dep’t of Soc. Servs., 436 U.S. 658 (municipal/contractor liability requires policy/custom showing)
West v. Atkins, 487 U.S. 42 (private contractors under color of state law when performing contractual duties)
Turner v. Safley, 482 U.S. 78 (prison regulations analyzed under Turner factors for reasonableness)