Paris Williams v. Jennifer Polemitis, et al.

Williams v. Polemitis · United States District Court for the Middle District of Pennsylvania · December 3, 2025 · No. 3:25-cv-02294

Summary

The United States District Court for the Middle District of Pennsylvania grants Paris Williams leave to proceed in forma pauperis but dismisses his 42 U.S.C. § 1983 complaint under 28 U.S.C. § 1915(e)(2)(B)(ii). The court concludes that allegations concerning the defendants’ handling and denial of prison grievances do not establish personal involvement in an underlying constitutional violation, while granting leave to amend.

Holdings

  1. Allegations that prison officials denied, reviewed, or participated in the post-incident grievance process do not, without more, establish the personal involvement necessary to impose § 1983 liability for an underlying constitutional violation.
  2. Inmates do not have a constitutionally protected right to a prison grievance process.
  3. Leave to amend should be granted because the complaint's deficiencies were largely factual and amendment was not shown to be inequitable or futile.

Questions Presented

  1. Whether Williams stated a claim under 42 U.S.C. § 1983 by alleging that prison officials denied or reviewed his grievances and appeals.
  2. Whether the complaint should be dismissed during preliminary screening for failure to allege the defendants' personal involvement in an underlying constitutional violation.
  3. Whether Williams should be granted leave to amend the deficient complaint.

Disposition

dismissed

Cases Cited (14)

  • Brodzki v. Tribune Co., 481 F. App'x 705, 706 (3d Cir. 2012) (per curiam)(followed)
  • Mitchell v. Dodrill, 696 F. Supp. 2d 454, 471 (M.D. Pa. 2010)(followed)
  • Gonzaga Univ. v. Doe, 536 U.S. 273, 284-85 (2002)(followed)
  • Kneipp v. Tedder, 95 F.3d 1199, 1204 (3d Cir. 1996)(followed)
  • Mark v. Borough of Hatboro, 51 F.3d 1137, 1141 (3d Cir. 1995)(followed)
  • Emil Jutrowski v. Township of Riverdale, Jutrowski v. Twp. of Riverdale, 904 F.3d 280, 289 (3d Cir. 2018)(followed)
  • Rode v. Dellarciprete, 845 F.2d 1195, 1207 (3d Cir. 1988)(followed)
  • Dooley v. Wetzel, 957 F.3d 366, 374 (3d Cir. 2020)(followed)
  • Jackson v. Gordon, 145 F. App'x 774, 777 (3d Cir. 2005) (per curiam)(followed)
  • Pressley v. Beard, 266 F. App'x 216, 218 (3d Cir. 2008)(followed)

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Cited In (0)

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