Troy Coulston v. Steven Glunt
665 F. App'x 128
3rd Cir.2016Background
- Plaintiff Troy Coulston, a Pennsylvania state inmate, sued under 42 U.S.C. § 1983 and state tort law after CO Wilt allegedly slammed a steel door on his leg/back in May 2012 and threatened him.
- Coulston named CO Wilt and five identified prison officials (and a John Doe mail clerk) alleging excessive force, retaliation, due process/equal protection violations, and various state-law claims.
- The district court denied dismissal of Coulston’s retaliation and assault claims but dismissed other federal claims at the Rule 12(b)(6) stage and denied leave to amend as futile.
- On summary judgment, the district court granted judgment for defendants on excessive force and retaliation claims (and declined supplemental jurisdiction over state-law claims).
- The Third Circuit affirmed summary judgment, finding Coulston’s factual account blatantly contradicted by video evidence and that he failed to exhaust administrative remedies for the retaliation claim.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Excessive force (Eighth Amendment) | Wilt slammed the door on Coulston, trapped him, threatened him, and caused injury. | Video and medical evidence show force used to restore order, not to inflict punishment; injuries were minor/chronic. | Court: Grant summary judgment for Wilt — plaintiff’s account contradicted by video; no malicious/sadistic force. |
| Retaliation | Coulston alleges Wilt threatened retaliation for pursuing complaints. | Coulston failed to exhaust administrative remedies; did not grieve retaliation claim. | Court: Grant summary judgment for defendants for failure to exhaust; Coulston’s fear excuse not credible. |
| Due process / property/liberty interest | Coulston claims entitlement to investigation and police notification after assault. | No cognizable liberty or property interest in having staff investigate/notify police. | Court: Dismiss — no protected liberty or property interest under Sandin. |
| Equal protection | Coulston alleges disparate treatment because he is an inmate. | Inmates are not a suspect class; staff are not similarly situated to inmates. | Court: Dismiss — no equal protection violation; no similarly situated comparator and rational basis absent. |
Key Cases Cited
- Sandin v. Conner, 515 U.S. 472 (determination of protected liberty interest requires atypical and significant hardship)
- Scott v. Harris, 550 U.S. 372 (video that blatantly contradicts plaintiff’s account can defeat claim at summary judgment)
- Smith v. Mensinger, 293 F.3d 641 (Eighth Amendment excessive force test: malicious and sadistic vs. good-faith discipline)
- Whitley v. Albers, 475 U.S. 312 (force used during prison security measures not cruel and unusual merely because it appears unreasonable in hindsight)
- Celotex Corp. v. Catrett, 477 U.S. 317 (summary judgment burden-shifting framework)
- Anderson v. Liberty Lobby, 477 U.S. 242 (standard for genuine dispute of material fact at summary judgment)
- Bell Atlantic Corp. v. Twombly, 550 U.S. 544 (facial plausibility standard for Rule 12(b)(6) dismissal)