Jonathan DiFraia v. Kevin Ransom

Summary

The U.S. Court of Appeals for the Third Circuit affirmed dismissal of Jonathan DiFraia’s Eighth Amendment and Americans with Disabilities Act claims arising from his removal from a prison medication-assisted treatment program after officials suspected him of diverting Suboxone. The court held that the allegations did not plausibly establish deliberate indifference or ADA causation. It vacated dismissal of his Pennsylvania negligence claim and remanded because intervening Supreme Court precedent abrogated the circuit precedent requiring a certificate of merit in federal court.

Holdings

1. DiFraia failed to state an Eighth Amendment claim because his allegations showed, at most, a disagreement with prison officials' medical judgment and did not plausibly establish subjective deliberate indifference to a serious medical need.
2. DiFraia failed to state a Title II ADA claim because he did not plausibly allege that his disability was the but-for cause of his exclusion from the treatment program or that denial of Suboxone was a failure to provide a reasonable accommodation.
3. The District Court improperly dismissed the state-law negligence claim under Pennsylvania Rule of Civil Procedure 1042.3 because controlling precedent requiring application of that state certificate-of-merit rule in federal court had been abrogated by the Supreme Court.

Questions Presented

1. Whether DiFraia plausibly alleged that prison officials were deliberately indifferent to serious medical needs in violation of the Eighth Amendment.
2. Whether removing DiFraia from the Medication Assisted Treatment program because he was accused of diverting Suboxone violated Title II of the Americans with Disabilities Act.
3. Whether the District Court properly dismissed DiFraia's Pennsylvania negligence claim for failure to file a certificate of merit under Pennsylvania Rule of Civil Procedure 1042.3.

Disposition

other