Joey Hoffman v. Jillian Cuffaro, et al.

Summary

The United States District Court for the Middle District of Pennsylvania grants Joey Hoffman leave to amend but dismisses his amended § 1983 complaint under 28 U.S.C. § 1915(e)(2)(B)(ii). The court dismisses claims against certain supervisory and grievance-review defendants, as well as the Fifth, Eighth, and Fourteenth Amendment claims, and grants a final opportunity to amend claims dismissed without prejudice; the motion for default judgment is deemed withdrawn.

Holdings

1. The court granted Plaintiff's motion to amend, filed the proposed amended complaint as a separate docket entry, and screened it.
2. The amended complaint failed to state supervisory-liability claims against the warden and unit manager because it alleged only their supervisory status and did not plead the facts required to show a deficient supervisory practice, awareness of risk, deliberate indifference, and resulting constitutional injury.
3. The amended complaint failed to state a § 1983 claim against Defendant Rodriguez based solely on his alleged denial of Plaintiff's grievances.
4. The amended complaint failed to state a First Amendment access-to-courts claim because Plaintiff did not allege that he lost a nonfrivolous or arguable underlying claim and lacked another remedy for that loss.
5. Plaintiff's Fifth Amendment claim failed as a matter of law and was dismissed with prejudice because the Fifth Amendment's Due Process Clause restricts federal governmental action, not state or county action.
6. The Eighth Amendment claim was dismissed with prejudice because the Eighth Amendment does not apply until an inmate has been convicted and sentenced.
7. The amended complaint failed to state a Fourteenth Amendment claim because Plaintiff did not plausibly allege that the challenged conditions of confinement amounted to punishment, and the claim was dismissed with prejudice.
8. The motion for default judgment was deemed withdrawn because Plaintiff did not file the required supporting brief within the time required by Local Rule 7.5.

Questions Presented

1. Whether Plaintiff should be permitted to file the proposed amended complaint.
2. Whether the amended complaint stated a First Amendment access-to-courts claim based on the denial of paper, envelopes, and copies.
3. Whether the amended complaint stated supervisory-liability claims against the warden and unit manager.
4. Whether the amended complaint stated a § 1983 claim against the grievance coordinator based solely on denial or review of grievances.
5. Whether Plaintiff could pursue Fifth Amendment due process or equal-protection claims against county prison employees.
6. Whether a pretrial detainee could pursue the asserted Eighth Amendment claim and whether the allegations stated a Fourteenth Amendment conditions-of-confinement claim.
7. Whether Plaintiff's unsupported motion for default judgment should be deemed withdrawn under Local Rule 7.5.

Disposition

other