Abraham Sigurd Lee v. SCI Camp Hill, et al.

Summary

The United States District Court for the Middle District of Pennsylvania dismisses Abraham Sigurd Lee’s pro se 42 U.S.C. § 1983 complaint under 28 U.S.C. § 1915A(b)(1) for failure to state a claim. The court rejects claims concerning rejected privileged mail, access to the courts, procedural due process, and liability of SCI Camp Hill, prison officials, and Cumberland County. The court grants limited leave to amend, while dismissing with prejudice claims against SCI Camp Hill and the First Amendment challenge to the Pennsylvania Department of Corrections’ legal-mail coding policy.

Holdings

1. A Section 1983 plaintiff must plead facts showing each defendant's personal involvement in the alleged constitutional misconduct; supervisory responsibility or respondeat superior liability is insufficient. Lee's allegation that Superintendent Gourley was responsible for employee actions and training did not plausibly allege personal involvement.
2. A state prison or state agency that is not a person within the meaning of Section 1983 cannot be sued under that statute. SCI Camp Hill is not a person subject to Section 1983 liability, and the claim against it was dismissed with prejudice.
3. A First Amendment free-speech challenge to Pennsylvania's requirement that privileged mail contain appropriate attorney or court control numbers fails where the same policy has already been upheld against constitutional challenge.
4. A backward-looking prisoner access-to-courts claim requires allegations of an actual injury consisting of the loss of a nonfrivolous or arguable underlying claim and the absence of another remedy. Lee's failure to identify an underlying claim, resulting injury, or lost remedy required dismissal.
5. Due process requires notice of a decision to censor or withhold incoming mail and a reasonable opportunity to challenge that decision before a different prison official. Lee received both safeguards, so he failed to state a procedural due process claim.
6. Lee's request for an injunction concerning SCI Camp Hill's mail policy was moot because he had been released from SCI Camp Hill and was no longer subject to the Pennsylvania Department of Corrections' mail policy.

Questions Presented

1. Whether Lee plausibly alleged personal involvement by Superintendent Michael Gourley sufficient to support Section 1983 liability.
2. Whether SCI Camp Hill is a person subject to suit under 42 U.S.C. § 1983.
3. Whether rejection of privileged mail lacking correct control coding stated a First Amendment free-speech claim.
4. Whether Lee plausibly alleged an actual injury and lack of an alternative remedy for an access-to-courts claim.
5. Whether the alleged rejection of incoming legal mail violated procedural due process.
6. Whether Lee stated a Section 1983 claim against Cumberland County or was entitled to prospective injunctive relief.

Disposition

dismissed