Vincent Franklin v. L. Hicks

Summary

The United States District Court for the Middle District of Pennsylvania granted defendant L. Hicks’s motion for summary judgment in Vincent Franklin’s 42 U.S.C. § 1983 class-of-one equal protection claim. The court held that Franklin, who was ordinarily administratively transferred, was not similarly situated to inmates transferred from SCI-Smithfield under COVID-19-specific guidance and that the differing compensation treatment had a rational basis.

Holdings

1. Franklin was not similarly situated to inmates transferred from SCI-Smithfield because he underwent an ordinary administrative transfer, while those inmates were transferred as part of SCI-Smithfield's designation as the system's single entry point for parole violators and new intakes.
2. Hicks had a rational basis for denying Franklin the prior rate of pay while preserving that rate for SCI-Smithfield transferees because DOC policy and COVID-19 guidance required the different treatment.
3. Summary judgment was warranted for Hicks because the undisputed factual record established that she did not violate Franklin's equal-protection rights.

Questions Presented

1. Whether Hicks violated Franklin's Fourteenth Amendment equal-protection rights under a class-of-one theory by denying him the same prison employment compensation received by inmates transferred from SCI-Smithfield.
2. Whether the undisputed record established that Franklin and the SCI-Smithfield transferees were not similarly situated and that the differential treatment had a rational basis.
3. Whether summary judgment was appropriate on the basis that Franklin failed to show a genuine dispute of material fact.

Disposition

other