Johnathan Wallace v. Lieutenant Gemmati, et al.

Summary

The United States District Court for the Middle District of Pennsylvania ruled on cross-motions for summary judgment in a pretrial detainee’s claims concerning conditions of confinement, medical care, and excessive force. The court granted summary judgment to the defendants on the conditions-of-confinement and medical-care claims and on the excessive-force claims against all defendants except C.O. Shearer. The excessive-force claim against Shearer survived because a reasonable jury could find that he used objectively unreasonable force after Wallace was subdued, and qualified immunity was denied at this stage.

Holdings

1. The defendants were entitled to summary judgment because Wallace presented no competent evidence that the conditions of his cell amounted to punishment under the Fourteenth Amendment.
2. The defendants were entitled to summary judgment on Wallace's medical-care claim because the record did not show deliberate indifference to a serious medical need.
3. Summary judgment was inappropriate on Wallace's excessive-force claim against Shearer because a reasonable jury could find that Shearer used objectively unreasonable force after Wallace had stopped resisting and was subdued.
4. Shearer was not entitled to qualified immunity at the summary-judgment stage because the evidence could establish a constitutional violation and the right not to be subjected to gratuitous force after being subdued was clearly established.
5. Wallace's claims for declaratory and injunctive relief were moot because he was no longer incarcerated at the Centre County Correctional Facility and there was no indication he would return.

Questions Presented

1. Whether defendants were entitled to summary judgment on Wallace's Fourteenth Amendment conditions-of-confinement claim.
2. Whether defendants were entitled to summary judgment on Wallace's denial-of-medical-care claim.
3. Whether the evidence created a genuine dispute of material fact as to whether C.O. Shearer used objectively unreasonable force against Wallace after Wallace was subdued.
4. Whether C.O. Shearer was entitled to qualified immunity at the summary-judgment stage.
5. Whether Wallace's claims for declaratory and injunctive relief were moot because he was no longer housed at the facility.

Disposition

other