Tindell v. Department of Corrections
2014 Pa. Commw. LEXIS 187
Pa. Commw. Ct.2014Background
- Petitioners Tindell and Wright, pro se, seek mandamus relief in original jurisdiction against DOC, Secretary Wetzel, and SCI Forest officials Sauers, Burns, Tice, and Overmyer.
- They allege conditions in the Restricted Housing Unit (RHU) at SCI Forest violate DOC policies and create clearly established rights.
- Respondents move to dismiss via Rule 1028(a)(4) and seek dismissal of RHU staff as respondents, arguing lack of statewide officer status.
- Court clarifies mandamus relief is limited to ministerial acts and cannot compel discretionary actions or establish rights.
- Petitioners also seek Eighth Amendment relief for cruel and unusual punishment due to medical care denial and confinement conditions.
- Court ultimately dismisses the petition, concluding petitioners failed to plead a clear right to relief or deliberate indifference by respondents.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether mandamus can compel discretionary prison decisions | Tindell argues mandamus can enforce DOC policies in RHU conditions. | Respondents contend mandamus cannot compel discretionary action, only ministerial acts. | Demurrer sustained; mandamus cannot compel discretionary actions. |
| Whether petition alleges a clear right to relief under Eighth Amendment for denial of medical care | Tindell asserts deliberate indifference to serious medical needs (diabetes) in RHU. | Respondents contend no facts show deliberate indifference by named respondents. | No cognizable mandamus claim established; lack of deliberate indifference allegations. |
| Whether petition alleges cruel and unusual punishment due to RHU conditions | Petitioners claim temperature, ventilation, noise, and other RHU conditions violate Eighth Amendment. | Respondents argue mandamus cannot adjudicate Eighth Amendment claims by assessing overall conditions. | Petition rejected; lack of facts showing deliberate indifference by specific respondents. |
| Whether First Amendment retaliation claims are cognizable in mandamus | Petitioners contend behavior modification constitutes retaliation under First Amendment. | No protected conduct alleged or causal link shown between conduct and adverse action. | Demurrer sustained as to First Amendment claims. |
| Whether RHU staff are proper respondents under Section 761(a) original jurisdiction | Petitioners include RHU personnel as respondents for alleged rights violations. | RHU staff are not statewide officers with original jurisdiction. | Court not addressing this objection on the merits due to dismissal on other grounds. |
Key Cases Cited
- Estelle v. Gamble, 429 U.S. 97 (Supreme Court 1976) (deliberate indifference to serious medical needs violates Eighth Amendment)
- Farmer v. Brennan, 511 U.S. 825 (Supreme Court 1994) (requirement of deliberate indifference; subjective standard)
- Wilson v. Seiter, 501 U.S. 294 (Supreme Court 1991) (deliberate indifference standard in conditions of confinement)
- Rhodes v. Chapman, 452 U.S. 337 (Supreme Court 1981) (conditions of confinement not necessarily cruel and unusual punishment by themselves)
- DeShaney v. Winnebago Cnty. Soc. Servs., 489 U.S. 189 (Supreme Court 1989) (State responsibility for basic human needs when restraining liberty)