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Wyatt v. Hauser
1:22-cv-00092
M.D. Penn.
Mar 11, 2025
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Background

  • Plaintiff Tariq Wyatt, an inmate at SCI-Mahanoy, filed a pro se §1983 suit against multiple correctional staff alleging violations of First, Fifth, Eighth, and Fourteenth Amendments.
  • Wyatt’s claims stemmed from incidents including a nurse dispensing medication without gloves, short-term psychiatric observation, written misconducts, alleged cold cell conditions, the taking of property, and responses to his grievances.
  • He alleged that these actions amounted to a retaliatory campaign against him, including "preemptive" retaliation for grievances he had not yet filed.
  • Throughout his incarceration, Wyatt filed 154 grievances, with eight relating specifically to these events. He never completed the full grievance process for any relevant grievance.
  • Both parties moved for summary judgment; the defendants’ motion was granted and plaintiff’s denied.

Issues

Issue Plaintiff's Argument Defendant's Argument Held
Failure to Exhaust Administrative Remedies Wyatt claims he used the grievance process for relevant complaints. Wyatt did not fully exhaust the three-tiered grievance appeal process. Plaintiff failed to exhaust remedies; claims barred.
Personal Involvement of Named Defendants Correctional officials personally involved by virtue of their roles. Most named defendants only tangentially involved (e.g., responding to grievances). No personal involvement shown; claims dismissed.
Constitutional Violations (Eighth Amendment, Due Process, Retaliation) Prison staff subjected plaintiff to harsh conditions and retaliatory treatment. No evidence of unconstitutional conditions or retaliation; actions justified and non-atypical. No constitutional violation; summary judgment to defendants.
Qualified Immunity Wyatt argues violations clear enough to overcome immunity. No established law requiring gloves for pill dispensing; actions reasonable. Defendants entitled to qualified immunity.

Key Cases Cited

  • Celotex Corp. v. Catrett, 477 U.S. 317 (summary judgment standard)
  • Anderson v. Liberty Lobby, Inc., 477 U.S. 242 (summary judgment standard)
  • Booth v. Churner, 532 U.S. 731 (PLRA exhaustion requirement is mandatory)
  • Porter v. Nussle, 534 U.S. 516 (PLRA exhaustion applies to all prison conditions suits)
  • Woodford v. Ngo, 548 U.S. 81 (proper exhaustion requires compliance with prison grievance procedures)
  • West v. Atkins, 487 U.S. 42 (defining 'person' under §1983)
  • Wilson v. Seiter, 501 U.S. 294 (Eighth Amendment conditions of confinement standards)
  • Farmer v. Brennan, 511 U.S. 825 (Eighth Amendment deliberate indifference standard)
  • Wolff v. McDonnell, 418 U.S. 539 (procedural due process in prison discipline)
  • Sandin v. Conner, 515 U.S. 472 (atypical, significant hardship required for due process claim)
  • Saucier v. Katz, 533 U.S. 194 (qualified immunity framework)
  • Hope v. Pelzer, 536 U.S. 730 (qualified immunity, clearly established law)
Read the full case

Case Details

Case Name: Wyatt v. Hauser
Court Name: District Court, M.D. Pennsylvania
Date Published: Mar 11, 2025
Docket Number: 1:22-cv-00092
Court Abbreviation: M.D. Penn.