Isaiah Best, et al. v. SCI-Phoenix, et al.

Summary

The Eastern District of Pennsylvania dismisses Michael James Mark Sinclair without prejudice as a named plaintiff because he neither paid the filing fees nor submitted an application to proceed in forma pauperis. The court grants Isaiah Best leave to proceed in forma pauperis but dismisses his claims, allowing amendment of certain claims while dismissing claims against immune or unsuitable defendants without leave to amend.

Holdings

1. A plaintiff who fails to pay the required filing fees or submit an adequate application to proceed in forma pauperis after being given an opportunity to cure may be dismissed from the action for failure to prosecute.
2. A § 1983 complaint must allege a constitutional or statutory deprivation by a person acting under color of state law and must identify each defendant's personal involvement in the alleged violation; collective allegations against 'Defendants' are insufficient.
3. Pennsylvania and its agencies, including the Pennsylvania Department of Corrections and SCI Phoenix, are not persons subject to § 1983 damages liability and are protected by Eleventh Amendment immunity from suits for money damages in federal court.
4. The United States and its agencies are generally immune from suits seeking money damages, and the United States has not waived sovereign immunity for constitutional or § 1983 claims.
5. A supervisor cannot be held liable under § 1983 merely because of his position; the plaintiff must plead particularized facts showing participation, direction, actual knowledge and acquiescence, or a deliberately indifferent policy, practice, custom, or failure to supervise or train that caused the constitutional injury.
6. When federal claims have been dismissed and the complaint does not establish complete diversity and the amount in controversy required by 28 U.S.C. § 1332(a), the court will not exercise supplemental jurisdiction over a state-law negligence claim.
7. The asserted damages claims under the Pennsylvania Constitution and the Universal Declaration of Human Rights are not legally actionable because Pennsylvania recognizes no private damages action under its Constitution and the Universal Declaration creates no private right of action.

Questions Presented

1. Whether Sinclair's claims should be dismissed because he failed to pay the filing fees or file an application to proceed in forma pauperis after being given an opportunity to cure.
2. Whether Best stated a plausible claim under 42 U.S.C. § 1983 against the named defendants based on the alleged prison conditions.
3. Whether Pennsylvania, the Pennsylvania Department of Corrections, and SCI Phoenix are persons subject to suit under § 1983 and whether they are immune from damages claims under the Eleventh Amendment.
4. Whether the United States is immune from claims for money damages based on alleged constitutional violations.
5. Whether Best adequately alleged personal involvement or supervisory liability against Superintendent Terra.
6. Whether the court had an independent basis for jurisdiction over Best's state-law negligence claim.
7. Whether claims under the Pennsylvania Constitution and the Universal Declaration of Human Rights were legally actionable.

Disposition

other