Randy Knox v. Secretary Department of Correc
669 F. App'x 611
| 3rd Cir. | 2016Background
- Randy Knox, a Pennsylvania prisoner proceeding pro se, sued under 42 U.S.C. § 1983 alleging Eighth Amendment denial of adequate medical care for a stomach hernia; he named prison officials and a treating physician.
- Knox alleged Dr. Mark Baker refused to order hernia surgery despite Knox’s repeated complaints and attached inmate request forms to the complaint.
- Defendants moved to dismiss under Rule 12(b)(6), arguing lack of personal involvement by Secretary Wetzel, Superintendent Harlow, and Health Care Administrator Overton; respondeat superior is insufficient for § 1983 liability.
- A Magistrate Judge recommended dismissal; Knox objected conceding Wetzel’s noninvolvement but claimed Harlow and Overton became involved via correspondence.
- The District Court adopted the R&R and dismissed the complaint for failure to allege personal involvement; the Court of Appeals summarily affirmed.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether defendants were deliberately indifferent to serious medical needs | Knox: prison officials and medical director refused surgery despite severe pain and requests | Defs: no personal involvement; Knox was treated by a prison doctor so non-medical officials not liable | Court: Dismissal affirmed — no facts showing personal involvement or deliberate indifference |
| Whether correspondence to administrators shows personal involvement | Knox: letters/correspondence to Harlow and Overton show they were involved | Defs: non-medical admins not liable merely for failing to override medical staff | Court: Correspondence insufficient; Durmer/Spruill bar liability when physician is treating the inmate |
| Whether respondeat superior suffices for § 1983 liability | Knox: named high-level officials as defendants | Defs: supervisory status alone not a basis for § 1983 liability | Court: Supervisory liability requires personal direction, knowledge, or acquiescence; respondeat superior insufficient |
| Whether failure to permit amendment was reversible error | Knox: District Court dismissed without formally granting leave to amend | Defs: Knox had opportunity in objections but failed to add facts | Court: Any error harmless; Knox had chance to amend in objections and did not do so |
Key Cases Cited
- Estelle v. Gamble, 429 U.S. 97 (Eighth Amendment deliberate indifference standard for inadequate medical care)
- Farmer v. Brennan, 511 U.S. 825 (Eighth Amendment subjective deliberate indifference test)
- Ashcroft v. Iqbal, 556 U.S. 662 (plausibility standard for complaints)
- Rode v. Dellarciprete, 845 F.2d 1195 (supervisory liability requires personal involvement)
- Durmer v. O’Carroll, 991 F.2d 64 (non-medical officials not liable when prisoner is treated by physician)
- Spruill v. Gillis, 372 F.3d 218 (scope of non-medical official liability where medical staff are involved)
- Tourscher v. McCullough, 184 F.3d 236 (standard of appellate review of dismissal)
- Murray v. Bledsoe, 650 F.3d 246 (summary affirmance when no substantial question)
- Grayson v. Mayview State Hosp., 293 F.3d 103 (leave to amend before dismissal)