Tyree Lawson v. Brenda Haupt, 677 F. App'x 43

Tyree Lawson, an inmate at SCI-Forest, sued under 42 U.S.C. § 1983 alleging Corrections Unit Manager Brenda Haupt transferred him from I Unit (allegedly "privileged" housing) to F Unit in retaliation for filing a grievance appeal.
Lawson claimed F Unit and his cellmate were "problematic," and the transfer was punitive.
Haupt moved Lawson on December 4, 2014, asserting institutional housing needs: incoming inmates with outside-clearance (R code) or job-based requirements needed I Unit beds. Lawson lacked R clearance and qualifying job assignments.
Parties filed cross-motions for summary judgment; the magistrate judge (with consent) granted Haupt summary judgment and denied Lawson’s motion; Lawson’s reconsideration motion was denied.
The Third Circuit exercised plenary review and summarily affirmed, finding Lawson established protected activity but failed to show adverse action or causation, and Haupt produced unrebutted evidence she would have transferred him for legitimate penological reasons.
The court also held amendment would be futile because Haupt showed she would have transferred Lawson absent the grievance.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the transfer was an "adverse action" for First Amendment retaliation	Transfer from I Unit (an "honor/privileged" unit) deprived Lawson of privileges and thus was adverse	Lawson failed to show I Unit conferred unique rights or benefits; no constitutional right to specific housing	Transfer not shown to be adverse; summary judgment for Haupt
Whether there was causation between grievance and transfer	Transfer occurred after grievance filing, implying retaliatory motive	Haupt showed non-retaliatory penological reasons and that transfers were routine to make bed space for incoming R-code/job inmates	No causal connection proven; lawful penological reasons would have led to same transfer
Whether summary judgment was appropriate	Lawson argued genuine disputes existed over motive and adverse action	Haupt met summary judgment burden with affidavit/evidence; Lawson did not produce contrary specific facts	Summary judgment appropriate; no genuine dispute of material fact
Whether amendment of complaint should be allowed	Impliedly sought leave to amend to better plead adverse action	Court found amendment futile because Haupt established she would have transferred Lawson regardless	Amendment would be futile; dismissal affirmed

Celotex Corp. v. Catrett, 477 U.S. 317 (summary judgment burdens and procedures)
Anderson v. Liberty Lobby, Inc., 477 U.S. 242 (summary judgment and genuine issue standard)
Olim v. Wakinekona, 461 U.S. 238 (no constitutional right to specific prison housing)
Rauser v. Horn, 241 F.3d 330 (3d Cir. standard for prisoner retaliation claims)
Giles v. Kearney, 571 F.3d 318 (standard of review for district court orders)