Thurman Mearin v. Pete Vidonish, 450 F. App'x 100

Mearin, pro se, is in Pennsylvania DOC custody at SCI-Greene after transfer from SCI-Graterford in July 2005.
He alleges retaliation by SCI-Greene staff upon learning he pursued a lawsuit against a SCI-Graterford official, including theft and destruction of items.
Mearin claims falsified documents led to 256 days in RHU beginning February 2006, followed by 343 more RHU days starting November 2006 for self/others danger.
In November 2008, Mearin filed a second amended complaint under 42 U.S.C. § 1983 against numerous DOC employees.
The District Court granted summary judgment to defendants on all claims after dismissing due process but allowing retaliation claim to proceed, which was later resolved in favor of defendants.
This appeal challenges the district court’s grant of summary judgment on the retaliation claim and related due process issues.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether RHU/detention constitutes a liberty interest	Mearin asserts due process rights were violated due to RHU placements.	No cognizable liberty interest; placements not atypical or significant.	No cognizable liberty interest; due process claim fails.
Whether Mearin's retaliation claim survives summary judgment	Defendants retaliated for filing a lawsuit.	No causal link shown; defendants lacked knowledge of the suit during adverse actions.	Summary judgment affirmed; no causal evidence of retaliation.
Whether claims relating to RHU conditions support relief	RHU environment was more restrictive and punitive.	RHU conditions not sufficiently atypical or significant.	RHU conditions do not show a due process violation.

Sandin v. Connor, 515 U.S. 472 (1995) (liberty interest requires atypical and significant hardship)
Shoats v. Horn, 213 F.3d 140 (3d Cir. 2000) (consider duration and conditions of segregation)
Griffin v. Vaughn, 112 F.3d 703 (3d Cir. 1997) (15 months in administrative custody not atypical)
Milhouse v. Carlson, 652 F.2d 371 (3d Cir. 1981) (protected activity includes grievances and lawsuits)
Carter v. McGrady, 292 F.3d 152 (3d Cir. 2002) (retaliation requires protected conduct, adverse action, and causation)
Rauser v. Horn, 241 F.3d 330 (3d Cir. 2001) (causation must be shown for retaliation claims)
Ashcroft v. Iqbal, 129 S. Ct. 1937 (2009) (pleading standard requires plausibility)
Beers-Cowell v. Whetzel, 256 F.3d 120 (3d Cir. 2001) (summary judgment standard in Third Circuit)
United States v. Agnew, 407 F.3d 193 (3d Cir. 2005) (broad authority to affirm on any record-supported basis)