WOODELL v. PA. DEPARTMENT OF CORRECTIONS AT GRATERFORD
2:18-cv-01098
E.D. Pa.Aug 30, 2019Background
- Pro se prisoner Rancourt Woodell sued ~76 defendants (individual medical and DOC staff plus contractors CCS and Wexford) under 42 U.S.C. § 1983 alleging (inter alia) Eighth Amendment deliberate indifference to seizures/panic attacks, access-to-courts interference, grievance-policy changes, and Monell liability.
- Woodell filed numerous grievances; the amended complaint incorporated many grievance numbers and spanned incidents from 2005–2018. He sought injunctive relief and a medical exam.
- Defendants moved to dismiss under Rule 12(b)(6), principally arguing most claims are time-barred and the timely allegations fail to state a claim; many state-entity and official-capacity claims raise Eleventh Amendment or "not a person" problems.
- The district court applied the two-year § 1983 limitations rule (with PLRA tolling for exhaustion), rejected a "continuing violation" tolling theory, and parsed exhaustion/grievance final-decision dates to determine timeliness.
- The court dismissed the bulk of claims with prejudice as time-barred, dismissed state entities and official-capacity monetary claims based on Eleventh Amendment/Will, and dismissed numerous individual claims for failure to plead personal involvement or to allege plausibly deliberate indifference; some timely claims were dismissed without prejudice and leave to amend was provided.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Statute of limitations (timeliness) | Many injuries continued; tolling applies; grievances exhausted so claims timely | Two-year Pennsylvania limitations applies; most alleged acts occurred outside window; continuing-violation doctrine inapplicable | Majority of claims (notably relating to Rockview and Fayette) are time-barred and dismissed with prejudice; a few Graterford/Phoenix grievances remained timely and survived only provisionally |
| Eleventh Amendment / capacity of state entities under § 1983 | Sued DOC, SCIs, Bureau, and officials in official and individual capacities for relief | State entities are not "persons" under § 1983 and Eleventh Amendment bars monetary suits against the Commonwealth and its agencies | Monell claims against DOC/SCIs/Bureau and official-capacity monetary claims dismissed (Eleventh Amendment/Will); injunctive relief against officials in official capacity remains theoretically available |
| Personal involvement / supervisory liability | Group or catchall allegations ("Commonwealth Defendants") and grievance reviewers personally responsible | Liability requires individual "personal involvement" (not respondeat superior); grievance review alone insufficient | Claims asserting only group membership, supervisory status, or grievance-review were dismissed (often without prejudice) for failure to plead personal involvement with particularity |
| Eighth Amendment deliberate indifference / Monell | Defendants denied, delayed, or substituted improper treatment for seizures causing serious harm; contractors (CCS, WHC) responsible via policy/custom or failure to train | Allegations are often conclusory, reflect disagreement or negligence, or rely on respondeat superior; Monell requires a municipal/custom/policy or deliberate failure-to-train showing and a predicate constitutional violation | Most deliberate-indifference claims were dismissed (many as time-barred); a limited number of timely claims (e.g., grievance #631559/#603733/#716882 issues re: Dr. Wiener and prescriptions) were dismissed without prejudice to replead; Monell claims against CCS/WHC dismissed without prejudice for failure to plead policy/custom with specificity |
Key Cases Cited
- Will v. Michigan Dep’t of State Police, 491 U.S. 58 (state entities and officials sued in official capacity are not "persons" for § 1983 monetary relief)
- Monell v. Department of Social Services of the City of New York, 436 U.S. 658 (municipal liability under § 1983 requires an official policy, custom, or deliberate failure to train)
- Bell Atl. Corp. v. Twombly, 550 U.S. 544 (pleading must contain factual content making claim plausible)
- Ashcroft v. Iqbal, 556 U.S. 662 (each government-official defendant must be alleged to have violated plaintiff’s rights through own conduct)
- Estelle v. Gamble, 429 U.S. 97 (deliberate indifference to serious medical needs violates the Eighth Amendment)
- City of Canton v. Harris, 489 U.S. 378 (Monell failure-to-train theory requires deliberate indifference by policymakers)
- Hafer v. Melo, 502 U.S. 21 (state officials sued in their individual capacities are "persons" under § 1983)
- Spruill v. Gillis, 372 F.3d 218 (3d Cir.) (non‑medical officials may rely on medical staff; deliberate indifference requires actual knowledge and disregard)