William Harris v. Brian Hyde, 709 F. App'x 144

In 2014 Harris, a prisoner at SCI–Somerset, had prescribed knee braces confiscated when transferred to the Restricted Housing Unit; they were returned on December 28, 2014.
Harris filed grievances claiming: (1) Corrections Healthcare Administrator Brian Hyde delayed return of the braces (deliberate indifference / inadequate medical care), and (2) Lieutenants Kinzey and Harr conditioned return on withdrawing grievances (retaliation).
Hyde’s affidavit stated the braces were confiscated per RHU policy and returned after medical review; medical staff monitored Harris during the month without braces.
Grievance process: an initial grievance about the braces was denied (noting Harris was told to sign up for sick call), and a retaliation grievance against Kinzey and Harr was deemed frivolous by the grievance officer.
The District Court granted summary judgment for defendants on medical-care, conspiracy, due-process, and later on retaliation; the Court found no evidence of deliberate indifference by Hyde and concluded Harris failed to show an adverse action for retaliation.
On appeal the Third Circuit affirmed: it held Harris failed to show Hyde’s deliberate indifference and additionally failed to exhaust administrative remedies for the retaliation claim.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Eighth Amendment deliberate indifference re: delay returning knee braces	Harris: Hyde failed to review records/authorize return sooner, causing denial of serious medical need	Hyde: Braces confiscated per policy; medical staff monitored Harris and he was told to sign up for sick call; no deliberate indifference	Affirmed for defendants—no evidence Hyde acted with deliberate indifference; non-physician supervision insufficient to show liability where medical staff already treated plaintiff
First Amendment retaliation for filing grievances (Kinzey, Harr)	Harris: Officers conditioned return of braces on withdrawing grievances, which is retaliatory and an adverse action	Defendants: No adverse action because braces were not available for use during investigation; also defendants asserted Harris failed to exhaust appeals	Affirmed—Court found failure to exhaust administrative remedies; District Court had also found no adverse action on the merits

Giles v. Kearney, 571 F.3d 318 (3d Cir. 2009) (summary judgment standard review)
Christ the King Manor, Inc. v. Sec’y U.S. Dep’t of Health & Human Servs., 730 F.3d 291 (3d Cir. 2013) (appellate court may affirm on any basis supported by the record)
Durmer v. O’Carroll, 991 F.2d 64 (3d Cir. 1993) (non‑physician supervisors not liable for deliberate indifference when prisoner is being treated by medical staff)
Porter v. Nussle, 534 U.S. 516 (2002) (PLRA exhaustion requirement applies to all inmate suits about prison life)
Booth v. Churner, 206 F.3d 289 (3d Cir. 2000) (prisoner must pursue grievance procedures fully to exhaust administrative remedies)
Tabron v. Grace, 6 F.3d 147 (3d Cir. 1993) (standard for appointment of counsel in civil cases)