Naguib Muhammad v. Sergeant Piston, et al.

Summary

The United States District Court for the Eastern District of Pennsylvania grants Naguib Muhammad leave to proceed in forma pauperis and screens his 42 U.S.C. § 1983 complaint under 28 U.S.C. § 1915(e)(2)(B). The court allows excessive-force and failure-to-intervene claims arising from the July 28, 2025 incident to proceed against several correctional officials, while dismissing other claims with prejudice or without prejudice. The dismissed claims include official-capacity claims, failure-to-investigate claims, grievance-process claims, inadequately pleaded supervisory-liability claims, and undeveloped retaliation claims.

Holdings

1. The complaint plausibly alleged Eighth Amendment excessive-force claims against Piston, Harris, and Patterson because it alleged that force was used against a handcuffed prisoner in a manner that could have been malicious and sadistic rather than in a good-faith effort to maintain or restore discipline.
2. The complaint plausibly alleged a § 1983 failure-to-intervene claim against Grinivich.
3. Any excessive-force claim based on Piston's alleged shove during the July 26, 2025 cell search was dismissed without prejudice as insufficiently pleaded.
4. The complaint did not plausibly allege supervisory liability against Terra, Kertes, and Dusel based solely on failure to supervise or their high-ranking positions.
5. Claims against Hartless and Rapp based on failure to investigate or report the alleged assault were dismissed with prejudice.
6. Claims based on alleged destruction or obstruction of Muhammad's grievance paperwork were dismissed with prejudice because prisoners have no independent constitutional right to a prison grievance process.
7. The First Amendment retaliation claims against Terra, Kertes, and Dusel were dismissed without prejudice.
8. Official-capacity damages claims against the prison-official defendants were dismissed with prejudice.

Questions Presented

1. Whether the complaint plausibly alleged Eighth Amendment excessive-force claims against Piston, Harris, and Patterson based on the July 28, 2025 incident.
2. Whether the complaint plausibly alleged an Eighth Amendment failure-to-intervene claim against Grinivich.
3. Whether the complaint stated a plausible excessive-force claim based on Piston's alleged July 26, 2025 shove during a cell search.
4. Whether the complaint plausibly alleged supervisory liability against Terra, Kertes, and Dusel.
5. Whether officials' alleged failure to investigate or discipline prison personnel stated a constitutional claim.
6. Whether interference with or destruction of prison grievance paperwork stated an independent constitutional claim.
7. Whether the complaint plausibly alleged First Amendment retaliation based on placement in the POC unit.
8. Whether official-capacity damages claims against Pennsylvania Department of Corrections employees were barred.

Disposition

other