Riley v. Clark
4:20-cv-00325
M.D. Penn.Mar 31, 2025Background
- Plaintiffs, including Carmen Riley, filed civil rights and tort claims related to the death of an individual detained at Dauphin County Prison in Pennsylvania.
- Multiple defendants were named, including county and township officials, prison staff, and a medical contractor (PrimeCare Medical, Inc.).
- The claims involved allegations of excessive force, failures to intervene, inadequate medical care, and failures in training and supervision, as well as state law claims of negligence, assault, battery, wrongful death, and survivor action.
- After extensive discovery, various defendants moved for summary judgment on all claims.
- The District Court reviewed the Magistrate Judge’s Report and Recommendation (R&R), adopting some recommendations and rejecting others, resulting in the dismissal of some claims against certain defendants and denial of summary judgment for others.
- Several defendants were terminated from the case, but specific claims (notably on excessive force and related state law torts against a subset of individual defendants) survived summary judgment, proceeding toward trial.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Conspiracy under § 1983 | Defendants conspired to violate decedent's rights | No evidence of conspiracy | Summary judgment for all defendants |
| Excessive Force under § 1983 | Use of force was unreasonable and caused death | Force was reasonable or justified | Most defendants granted summary judgment; some denied |
| Failure to Intervene under § 1983 | Officers failed to prevent unconstitutional acts | Officers had no realistic opportunity | Mixed; some defendants denied summary judgment |
| Medical Negligence | PrimeCare failed to provide adequate care | Compliance with standard of care | Summary judgment for PrimeCare |
| Assault and Battery | Use of force constituted assault and battery | Force used was lawful | Mixed; some defendants denied summary judgment |
| Wrongful Death / Survival Act | Defendants' actions caused death | No causation or immunity | Most defendants granted summary judgment; some denied |
| IIED | Conduct was extreme and outrageous | Conduct not legally sufficient | Summary judgment for all defendants |
Key Cases Cited
- No official reporter citations were referenced in the provided opinion text.
