Small v. McMullin, 1:14-cv-00692

Warren Small, a pro se Delaware prison inmate, filed a § 1983 suit alleging excessive force, denial of due process at disciplinary hearings, and related mistreatment at Howard R. Young Correctional Institution; he proceeded in forma pauperis and amended his complaint.
Key incidents: on March 6, 2014, correctional officers R. Massi and Loy allegedly sprayed Small with pepper spray while he was behind a locked door and posed no threat; other episodes involved alleged beatings, shackling, and use of a quick response team.
Small received disciplinary write-ups (hearings March 7 and later) resulting in 60 days in segregation and loss of 20 days good time; he alleges he did not timely receive notice of some charges, could not confront witnesses, and was denied an appeal form.
The amended complaint failed to state any specific allegations against several named supervisors (Warden Morgan, Ryder, Lt. William, Russel, Harris) or other staff (Franny, Hicks, Gayheard) as to personal involvement.
The Court screened the amended complaint under 28 U.S.C. §§ 1915(e)(2)(B) and 1915A and: (a) allowed excessive force claims to proceed against Massi and Loy; (b) allowed due-process notice claims to proceed against hearing officer McMillian and Sergeant Lee; and (c) dismissed supervisory claims, failure-to-confront claims, and certain other claims as frivolous or for failure to state a claim.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Excessive force by officers (Massi, Loy)	Massi and Loy sprayed Small with pepper spray while he was behind locked door and posed no threat	Implicit defense: force was justified for security/order (not detailed in opinion)	Allowed to proceed against Massi and Loy (claims survive screening)
Due process — notice of charges (McMillian, Lee)	Small was not timely provided written notice of disciplinary charges	Prison procedure satisfied Wolff/Hill requirements (implicit)	Allowed to proceed on claim that notice was not timely provided
Due process — right to confront witnesses	Small alleges he was not allowed to confront/cross-examine witnesses at hearings	Prison officials rely on discretion permitted by Wolff; confrontation not absolute right	Dismissed as frivolous/failing to state a claim — no federal right to unfettered confrontation
Supervisory liability / respondeat superior (Morgan, Ryder, William, Russel, Harris)	Supervisors are named as defendants based on position and alleged failures	Supervisory liability not automatic; personal involvement required	Dismissed as frivolous — no allegations of personal involvement or purposeful conduct to state § 1983 claim

Ashcroft v. Iqbal, 556 U.S. 662 (2009) (personal involvement and pleading standards; legal conclusions insufficient)
Bell Atl. Corp. v. Twombly, 550 U.S. 544 (2007) (pleading must state a plausible claim)
Wolff v. McDonnell, 418 U.S. 539 (1974) (procedural due process standards for prison disciplinary hearings)
Superintendent v. Hill, 472 U.S. 445 (1985) (disciplinary decisions must be supported by "some evidence")
Monell v. Department of Social Services, 436 U.S. 658 (1978) (municipal/supervisory liability principles under § 1983)
Neitzke v. Williams, 490 U.S. 319 (1989) (definition of frivolous suits under in forma pauperis screening)
Ball v. Famiglio, 726 F.3d 448 (3d Cir. 2013) (standards for dismissal under §§ 1915(e)(2) and 1915A)
Grayson v. Mayview State Hospital, 293 F.3d 103 (3d Cir. 2002) (leave to amend before dismissal unless futile)