Reichart v. Prison Health Services, SCI-Camp Hill, 1:11-cv-01992

Reichart, a pro se inmate at SCI-Camp Hill, sues Prison Health Services, Dr. Brent, and Premier Eye Care Group for alleged deliberate indifference and negligence in medical care.
Plaintiff claims failure to maintain policies for timely review of chronic-disease tests caused anticoagulant levels to stay outside therapeutic range (Mar–Dec 2011) and contributed to a poor cataract surgery outcome.
Left-eye cataract removal occurred on August 18, 2011, after a June 20, 2011 consult; Reichart never regained vision in the left eye.
Reichart alleges pre-surgical evaluation omitted consideration of irregular anticoagulant levels, allegedly increasing surgical risk.
Four inmate grievances (381094, 384855, 389396, 389071) regarding monitoring of blood levels and surgical outcomes were filed; none were appealed to final review per DC-ADM 804.
Defendants move for summary judgment arguing Reichart failed to exhaust administrative remedies under PLRA; court agreements on exhaustion and dismissal of §1983 claims.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Did Reichart properly exhaust administrative remedies?	Reichart contends DOC process was unavailable or improperly handled.	Reichart failed to appeal initial responses to final review as required.	Yes—claims dismissed for failure to exhaust.
Are Reichart's §1983 claims time-barred or procedurally defaulted due to non-exhaustion?	No viable exhaustion issues should bar the claim.	Exhaustion required; grievances not properly appealed to final review.	Claims dismissed for lack of proper exhaustion.
Should the court exercise supplemental jurisdiction over state-law negligence claims?	State claims should be heard alongside federal claims.	District court should dismiss state claims without prejudice to state court.	Dismissed without prejudice; no supplemental jurisdiction.

Woodford v. Ngo, 548 U.S. 81 (U.S. 2006) (proper exhaustion required; substantial compliance matters)
Spruill v. Gillis, 372 F.3d 218 (3d Cir. 2004) (procedural default for improper exhaustion)
Nyhuis v. Reno, 204 F.3d 65 (3d Cir. 2000) (exhaustion prerequisite; precludes claims without remedies)
Brown v. Croak, 312 F.3d 124 (3d Cir. 2002) (prison officials' interference defenses; procedural default considerations)
Porter v. Nussle, 534 U.S. 516 (U.S. 2002) (exhaustion mandatory across federal claims)
Celotex Corp. v. Catrett, 477 U.S. 317 (U.S. 1986) (summary judgment standard and burden shifting)
Matsushita Elec. Indus. Co. v. Zenith Radio Corp., 475 U.S. 574 (U.S. 1986) (genuine dispute standard; total record review)
Anderson v. Liberty Lobby, 477 U.S. 242 (U.S. 1986) (material facts; proof beyond doubt for jury trial thresholds)
Houston v. Lack, 487 U.S. 266 (U.S. 1988) (prison mailbox rule for filing dates)
Drippe v. Tobelinski, 604 F.3d 778 (3d Cir. 2010) (PLRA exhaustion standards; procedural defenses)