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