Sean Pressley v. Adam Huber
562 F. App'x 67
| 3rd Cir. | 2014Background
- Pressley, a pro se inmate, sues prison officials under §1983 for property deprivation, retaliation, and denial of access to courts.
- Claims stem from materials related to Pressley v. Horn; involvement of Huber and other officials is questioned.
- District Court dismissed several defendants for lack of personal involvement and dismissed others for failure to exhaust or timeliness.
- Huber confiscated and destroyed Pressley’s litigation materials after obtaining a list of open/closed cases; destruction occurred without notice that 04-2150 was active.
- Pressley’s grievance process and exhaustion status are at issue; the district court granted summary judgment to Huber on access-to-courts claim.
- Court reviews district court rulings de novo and defers to evidentiary findings at summary judgment if supported by record.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Liability of Marsh, Taggart, Kelchner, Beard for personal involvement | Pressley asserts these defendants were personally involved. | Huber argues no personal involvement by these defendants. | Affirmed dismissal for lack of personal involvement. |
| Due process claim for property deprivation against Huber | Destruction of files violated his property rights. | Post-deprivation remedies suffice; no due process violation if remedies exist. | Affirmed summary judgment against Pressley on due process claim. |
| Timeliness of retaliation claim against Huber under statute of limitations | Exhaustion tolls limitations; claim timely. | Claim untimely; exhaustion tolling not controlling here. | Retaliation claim time-barred. |
| Exhaustion and accrual of §1983 access-to-courts claim against Huber | Grievance filing and destruction impeded exhaustion; tolling applies. | Grievance processing completed or not; no tolling shown. | Huber entitled to summary judgment on access-to-courts claim. |
| Whether summary judgment was proper given record of negligent vs. intentional conduct | Huber’s actions were deliberate and targeted. | Record shows at most negligence; no deliberate interference. | Summary judgment proper for Huber. |
Key Cases Cited
- Ashcroft v. Iqbal, 556 U.S. 662 (U.S. 2009) (plausibility standard for pleading; not satisfied here)
- Daniels v. Williams, 474 U.S. 327 (U.S. 1986) (no due process remedy for negligent deprivation)
- Wallace v. Kato, 549 U.S. 384 (U.S. 2007) (accrual when plaintiff has complete, present cause of action)
- Hudson v. Palmer, 468 U.S. 517 (U.S. 1984) (no due process violation for unauthorized seizure absent state action)
- Evancho v. Fisher, 423 F.3d 347 (3d Cir. 2005) (personal involvement required for §1983 liability)
- Green v. Branson, 108 F.3d 1296 (10th Cir. 1997) (supervisor liability requires deliberate indifference in training)
- Rode v. Dellarciprete, 845 F.2d 1195 (3d Cir. 1988) (personal involvement required for §1983)
- Brown v. Pa. Dep’t of Health Emergency Med. Servs., 318 F.3d 473 (3d Cir. 2003) (affirms ability to affirm on alternative grounds)
- Knoll v. Springfield Twp. Sch. Dist., 763 F.2d 584 (3d Cir. 1985) (limitations tolling for exhaustion arguments considered)