Wilkerson v. Lycoming County Prison
3:25-cv-00411
M.D. Penn.Apr 29, 2025Background
- Robert Tamir Wilkerson, currently incarcerated at Lycoming County Prison, alleges unconstitutional conditions of confinement due to excessive lighting in the "DLU G-Block Unit."
- Wilkerson claims the lights are kept on for 22 hours per day, causing sleep deprivation, depression, and anxiety.
- Correctional officers allegedly removed inmates’ ability to control the lights and sanctioned inmates who attempted to cover them.
- Wilkerson filed this lawsuit pro se under 42 U.S.C. § 1983, naming Lycoming County Prison and its supervisory staff as defendants.
- The Court screened the complaint under 28 U.S.C. § 1915A and determined it did not state a claim upon which relief could be granted, but granted Wilkerson leave to amend within 30 days.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Conditions of Confinement under Eighth Amendment | Prison conditions are unconstitutional due to excessive lighting causing harm | Not stated, but prison as an entity cannot be sued and no personal involvement alleged | Complaint fails to state a claim; no personal involvement by defendants indicated |
| Proper Defendant under § 1983 | Sues Lycoming County Prison and supervisory staff | Lycoming County Prison is not a "person" under § 1983 | Lycoming County Prison cannot be sued under § 1983 |
| Personal Involvement of Supervisors | Supervisors are responsible as named defendants | Supervisors not personally involved; all actions attributed to unnamed officers | No personal involvement alleged; respondeat superior not sufficient |
| Pro Se Amendment Rights | Entitled to amend under liberal pro se standard | N/A | Plaintiff granted 30 days to amend complaint |
Key Cases Cited
- Ashcroft v. Iqbal, 556 U.S. 662 (complaints must contain sufficient factual matter to state a plausible claim)
- Bell Atlantic Corp. v. Twombly, 550 U.S. 544 (complaints require more than labels and conclusions for plausibility)
- Estelle v. Gamble, 429 U.S. 97 (pro se pleadings held to less stringent standards)
- Haines v. Kerner, 404 U.S. 519 (pro se complaints must be liberally construed)