Alfredo Rivera Lugo v. Rebecca Davis

CourtDistrict Court, M.D. Pennsylvania
DecidedJanuary 8, 2026
Docket4:25-cv-01781
StatusUnknown

This text of Alfredo Rivera Lugo v. Rebecca Davis (Alfredo Rivera Lugo v. Rebecca Davis) is published on Counsel Stack Legal Research, covering District Court, M.D. Pennsylvania primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Alfredo Rivera Lugo v. Rebecca Davis, (M.D. Pa. 2026).

Opinion

IN THE UNITED STATES DISTRICT COURT FOR THE MIDDLE DISTRICT OF PENNSYLVANIA

ALFREDO RIVERA LUGO, No. 4:25-CV-01781

Plaintiff, (Chief Judge Brann)

v.

REBECCA DAVIS,

Defendant.

MEMORANDUM OPINION

JANUARY 8, 2026 Plaintiff Alfredo Rivera Lugo filed the instant pro se Section 19831 lawsuit, alleging constitutional violations by an official at Lebanon County Prison. Lugo fails to state a claim upon which relief may be granted, so the Court will dismiss his complaint pursuant to 28 U.S.C. § 1915A(b)(1) but will grant him leave to amend. I. BACKGROUND Lugo’s complaint is brief and straightforward. He alleges that he was accused of sexual assault, but that the allegations were determined to be “unsubstantiated” following an investigation.2 Despite being cleared of the sexual

1 42 U.S.C. § 1983. Section 1983 creates a private cause of action to redress constitutional wrongs committed by state officials. The statute is not a source of substantive rights; it serves as a mechanism for vindicating rights otherwise protected by federal law. See Gonzaga Univ. v. Doe, 536 U.S. 273, 284-85 (2002). assault charge, Deputy Warden Rebecca Davis has refused to allow Lugo to return to minimum security housing.3 Lugo contends that he should be returned to his

previous custody classification and be permitted to return “to a lower security housing unit.”4 Lugo lodged the instant Section 1983 complaint in this Court in September 20255 and paid the initial partial filing fee in November. He maintains that Deputy

Warden Davis’s actions violate the Eighth Amendment’s prohibition of cruel and unusual punishments and infringe his equal protection rights under the Fourteenth Amendment.6 He seeks money damages and injunctive relief in the form of being

returned to lower security housing.7 II. STANDARDS OF REVIEW Courts are statutorily obligated to review, “as soon as practicable,” pro se prisoner complaints targeting governmental entities, officers, or employees.8 One

basis for dismissal at the screening stage is if the complaint “fails to state a claim upon which relief may be granted[.]”9 This language closely tracks Federal Rule of Civil Procedure 12(b)(6). Accordingly, courts apply the same standard to

3 See id. 4 Id. at 3. 5 See generally Doc. 1. 6 Id. at 3. 7 Id. 8 See 28 U.S.C. § 1915A(a). 9 Id. § 1915A(b)(1). screening a pro se prisoner complaint for sufficiency under Section 1915A(b)(1) as they utilize when resolving a motion to dismiss under Rule 12(b)(6).10

In deciding a Rule 12(b)(6) motion to dismiss, courts should not inquire “whether a plaintiff will ultimately prevail but whether the claimant is entitled to offer evidence to support the claims.”11 The court must accept as true the factual

allegations in the complaint and draw all reasonable inferences from them in the light most favorable to the plaintiff.12 In addition to the facts alleged on the face of the complaint, the court may also consider “exhibits attached to the complaint, matters of public record, as well as undisputedly authentic documents” attached to

a defendant’s motion to dismiss if the plaintiff’s claims are based upon these documents.13 When the sufficiency of a complaint is challenged, the court must conduct a three-step inquiry.14 At step one, the court must “tak[e] note of the elements [the]

plaintiff must plead to state a claim.”15 Second, the court should distinguish well- pleaded factual allegations—which must be taken as true—from mere legal

10 See Grayson v. Mayview State Hosp., 293 F.3d 103, 109-10 & n.11 (3d Cir. 2002); O’Brien v. U.S. Fed. Gov’t, 763 F. App’x 157, 159 & n.5 (3d Cir. 2019) (per curiam) (nonprecedential); cf. Allah v. Seiverling, 229 F.3d 220, 223 (3d Cir. 2000). 11 Scheuer v. Rhodes, 416 U.S. 232, 236 (1974); see Nami v. Fauver, 82 F.3d 63, 66 (3d Cir. 1996). 12 Phillips v. County of Allegheny, 515 F.3d 224, 229 (3d Cir. 2008). 13 Mayer v. Belichick, 605 F.3d 223, 230 (3d Cir. 2010) (citing Pension Benefit Guar. Corp. v. White Consol. Indus., 998 F.2d 1192, 1196 (3d Cir. 1993)). 14 Connelly v. Lane Const. Corp., 809 F.3d 780, 787 (3d Cir. 2016) (internal citations and quotation marks omitted) (footnote omitted). 15 Id. (quoting Ashcroft v. Iqbal, 556 U.S. 662, 675 (2009) (alterations in original)). conclusions, which “are not entitled to the assumption of truth” and may be disregarded.16 Finally, the court must review the presumed-truthful allegations

“and then determine whether they plausibly give rise to an entitlement to relief.”17 Deciding plausibility is a “context-specific task that requires the reviewing court to draw on its judicial experience and common sense.”18

Because Lugo proceeds pro se, his pleadings are to be liberally construed and his complaint, “however inartfully pleaded, must be held to less stringent standards than formal pleadings drafted by lawyers[.]”19 This is particularly true when the pro se litigant, like Lugo, is incarcerated.20

III. DISCUSSION As best as the Court can discern, Lugo is asserting an Eighth Amendment conditions-of-confinement claim and a Fourteenth Amendment equal protection

claim against Deputy Warden Davis. However, he fails to plausibly allege either type of Section 1983 cause of action. The Court will explain the deficiencies of each claim in turn.

16 Id. (quoting Iqbal, 556 U.S. at 679). 17 Id. (quoting Iqbal, 556 U.S. at 679). 18 Iqbal, 556 U.S. at 681. 19 Erickson v. Pardus, 551 U.S. 89, 94 (2007) (per curiam) (citations omitted). 20 Dooley v. Wetzel, 957 F.3d 366, 374 (3d Cir. 2020) (citation omitted). A. Eighth Amendment Conditions of Confinement “[T]he Constitution does not mandate comfortable prisons, and prisons . . .

which house persons convicted of serious crimes[] cannot be free of discomfort.”21 Nevertheless, the state cannot subject an inmate to cruel and unusual punishment or “inhumane treatment,” such as deprivation of “identifiable human need[s]” like “food, clothing, shelter, medical care, and reasonable safety[.]”22

To prevail on an Eighth Amendment conditions-of-confinement claim, a prisoner-plaintiff must plausibly allege both objective and subjective elements.23 Objectively, the inmate must demonstrate that “the prison official deprived the

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Related

Scheuer v. Rhodes
416 U.S. 232 (Supreme Court, 1974)
Moody v. Daggett
429 U.S. 78 (Supreme Court, 1976)
Rhodes v. Chapman
452 U.S. 337 (Supreme Court, 1981)
Helling v. McKinney
509 U.S. 25 (Supreme Court, 1993)
Gonzaga University v. Doe
536 U.S. 273 (Supreme Court, 2002)
Erickson v. Pardus
551 U.S. 89 (Supreme Court, 2007)
Ashcroft v. Iqbal
556 U.S. 662 (Supreme Court, 2009)
Mayer v. Belichick
605 F.3d 223 (Third Circuit, 2010)
Randolph Carson v. Richard Mulvihill
488 F. App'x 554 (Third Circuit, 2012)
Farmer v. Brennan
511 U.S. 825 (Supreme Court, 1994)
Phillips v. County of Allegheny
515 F.3d 224 (Third Circuit, 2008)
Village of Willowbrook v. Olech
528 U.S. 562 (Supreme Court, 2000)
Sandra Connelly v. Lane Construction Corp
809 F.3d 780 (Third Circuit, 2016)
Charles Mack v. Warden Loretto FCI
839 F.3d 286 (Third Circuit, 2016)
Renee Palakovic v. John Wetzel
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Casey Dooley v. John Wetzel
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Alfredo Rivera Lugo v. Rebecca Davis, Counsel Stack Legal Research, https://law.counselstack.com/opinion/alfredo-rivera-lugo-v-rebecca-davis-pamd-2026.