Williams v. Polemitis, et al.

Summary

The United States District Court for the Middle District of Pennsylvania screened Paris Williams’s amended 42 U.S.C. § 1983 complaint. The court dismissed the claims against Jennifer Polemitis, Tim Betty, Jason Talutto, and Colleen Orzel because their alleged involvement in reviewing or denying grievances did not establish personal involvement in an underlying constitutional violation. The court allowed an excessive-force claim against Correctional Officer Cadden to proceed and directed service of the amended complaint on Cadden.

Holdings

1. Williams failed to state a § 1983 claim against Polemitis, Betty, Talutto, and Orzel because allegations that they denied or reviewed his grievances and appeals did not establish personal involvement in the underlying alleged constitutional violation, and prisoners have no constitutional right to a prison grievance procedure.
2. Williams stated a plausible excessive-force claim against Cadden by alleging that Cadden pushed him without warning into a metal door, causing injury to his teeth.
3. Further leave to amend the claims against Polemitis, Betty, Talutto, and Orzel would be futile because Williams had already been granted leave to amend and failed to cure the personal-involvement deficiencies.

Questions Presented

1. Whether Williams adequately alleged personal involvement by Polemitis, Betty, Talutto, and Orzel in an underlying constitutional violation based on their handling or denial of his prison grievances and appeals.
2. Whether Williams plausibly stated an excessive-force claim against Cadden by alleging that Cadden pushed him without warning into a metal door, causing dental injuries.
3. Whether further leave to amend the claims against Polemitis, Betty, Talutto, and Orzel would be futile.

Disposition

other