Rhonshawn Jackson v. Jeffrey Beard
704 F. App'x 194
3rd Cir.2017Background
- Jackson, a Pennsylvania inmate, sued multiple DOC employees under 42 U.S.C. § 1983 for alleged mistreatment beginning after a March 19, 2009 riot and transfer to restrictive housing. Claims included excessive force, retaliation, denial of meals/showers/recreation, destroyed property, falsified disciplinary reports, failure to provide medical care, and obstruction of grievances.
- The District Court dismissed most claims under Rule 12(b)(6), leaving six claims related to alleged mistreatment at SCI-Huntingdon (June 2010–Jan 2011): two excessive-force claims, a retaliation claim, denial-of-meals, failure-to-protect, and a due-process grievance-obstruction claim.
- The District Court granted summary judgment for defendants on five of six remaining claims; it denied summary judgment on the failure-to-protect claim as "colorable" and referred exhaustion to a Magistrate Judge for an evidentiary hearing.
- After an evidentiary hearing the Magistrate Judge found Jackson failed to exhaust administrative remedies and found his obstruction allegations not credible; the District Court adopted that Report and entered judgment for defendants. Jackson’s motions for reconsideration were denied.
- On appeal Jackson (pro se) challenged the exhaustion finding, the timing of adoption of the R&R, the prior Rule 12(b)(6) dismissals, and the summary-judgment rulings. The Third Circuit affirmed.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether Jackson was obstructed from exhausting grievances (exhaustion) | Defendants prevented grievances from reaching final review by ripping, discarding, or ignoring them | Grievance records and staff affidavit show grievances were processed and Jackson simply failed to complete appeals | Court: Magistrate’s factual finding that Jackson did not exhaust and obstruction allegations not credible upheld; failure-to-protect claim dismissed for non-exhaustion |
| Whether evidentiary hearing implicated Seventh Amendment (right to jury) | Jackson claimed his retaliation/obstruction merits were intertwined with exhaustion, raising jury-right concerns | District Court: grievance-related retaliation claims had been dismissed years earlier and were not intertwined with exhaustion issues at hearing | Court: No Seventh Amendment problem; exhaustion hearing proper |
| Whether District Court erred by adopting R&R before receiving mailed objections | Jackson says he timely mailed objections which the court never received | District Court noted no received objections; Jackson later appended same objections to motion for reconsideration | Court: Timeliness dispute unnecessary to resolve; objections meritless and adoption affirmed |
| Whether Rule 12(b)(6) dismissals of various retaliation and property claims were improper | Jackson argued dismissals were erroneous, asserting retaliation claims and that confiscation was retaliatory | Defendants argued some claims time-barred, others not pleaded as retaliation or lacked alleged protected activity | Court: Affirmed dismissals — April 2009 claim time-barred; Nov 2010 claim properly treated as failure-to-protect; confiscation claim failed to plead protected activity |
Key Cases Cited
- Small v. Camden County, 728 F.3d 265 (3d Cir. 2013) (standard: de novo review of exhaustion determination after evidentiary hearing; accept factual findings unless clearly erroneous)
- Porter v. Nussle, 534 U.S. 516 (2002) (PLRA exhaustion applies to all inmate suits about prison life)
- Booth v. Churner, 206 F.3d 289 (3d Cir. 2000) (prisoner must follow all grievance steps to exhaust administrative remedies)
- Spruill v. Gillis, 372 F.3d 218 (3d Cir. 2004) (describing three-step DC-ADM 804 grievance process)
- Ashcroft v. Iqbal, 556 U.S. 662 (2009) (pleading standard: plausibility under Rule 12(b)(6))
- Bell Atl. Corp. v. Twombly, 550 U.S. 544 (2007) (pleading must state a plausible claim to relief)
- Kach v. Hose, 589 F.3d 626 (3d Cir. 2009) (applying state statute of limitations to § 1983 claims)
- Rauser v. Horn, 241 F.3d 330 (3d Cir. 2001) (elements of a retaliation claim require pleading protected activity)