Anthony McGriff v. Mrs. Cousins

CourtDistrict Court, M.D. Pennsylvania
DecidedOctober 30, 2025
Docket1:22-cv-01547
StatusUnknown

This text of Anthony McGriff v. Mrs. Cousins (Anthony McGriff v. Mrs. Cousins) 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
Anthony McGriff v. Mrs. Cousins, (M.D. Pa. 2025).

Opinion

UNITED STATES DISTRICT COURT MIDDLE DISTRICT OF PENNSYLVANIA

ANTHONY MCGRIFF,

Plaintiff, CIVIL ACTION NO. 1:22-cv-01547

v. (SAPORITO, J.)

MRS. COUSINS,

Defendant.

MEMORANDUM Defendant Jessica Tress1 requests reconsideration of the Court’s August 4, 2025, memorandum and order denying her motion for summary judgment. (Doc. 107). In the alternative, she requests that the Court certify an issue raised therein for interlocutory appeal. For the foregoing reasons, these requests will be denied, and the Court will attempt to obtain pro bono counsel to represent McGriff in this case. I. RECONSIDERATION A. Legal Standards Tress’s motion for reconsideration is necessarily brought pursuant to Rule 54(b) of the Federal Rules of Civil Procedure.

1 The defendant’s surname changed from Cousins to Tress while this case was pending. , 214 F. Supp. 3d 292, 295 (M.D. Pa. 2016). Under

Rule 54(b), “[a]n order that does not dispose of every claim in an action ‘may be revised at any time before the entry of a judgment adjudicating all the claims and all the parties’ rights and liabilities.’”

, 12 F. Supp. 3d 702, 717 (M.D. Pa. 2014) (quoting Fed. R. Civ. P. 54(b)); , 214 F. Supp. 3d at 295. Reconsideration of interlocutory orders “may be had even if a

movant cannot show an intervening change in controlling law, the availability of new evidence that was not available when the court issues the underlying order, or ‘the need to correct a clear error of law or fact or

to prevent manifest injustice.’” , 214 F. Supp. 3d at 295 (quoting , 176 F.3d 669, 677 (3d Cir. 1999)). “Instead, the court may permit reconsideration

whenever ‘consonant with justice to do so.’” (quoting , 412 F. Supp. 2d 630, 632 (M.D. Pa. 2007)); , 12 F. Supp. 3d at 717 (citing

, 487 F.2d 600, 605 (3d Cir. 1973)). Nevertheless, [b]efore entertaining a motion for reconsideration of an interlocutory order, the movant must still establish good cause for why the court should revisit its prior decision. Moreover, whether involving a final or interlocutory order, a motion for reconsideration is not to be used as a means to reargue matters already argued and disposed of or as an attempt to relitigate a point of disagreement between the Court and the litigant. A reconsideration motion should not be used to try to get a second bite at the apple or to raise new arguments or evidence that could have been proffered prior to the issuance of the order in question. , 214 F. Supp. 3d at 295-96 (citations and internal quotation marks omitted). B. Factual Background McGriff, a prisoner at SCI-Huntingdon with documented mental health issues2, proceeds on an Eighth Amendment claim of “deliberate indifference to medical care” against Tress, a nurse practitioner who specializes in psychiatry at the prison. McGriff had been prescribed Trazodone prior to his incarceration, and it was routinely renewed at

SCI-Huntingdon. In his complaint, McGriff alleged that prior to August 7, 2020, he received his daily dose of Trazodone in his cell, at night, because of COVID-19 protocols.

The summary judgment record indicated as follows: At

2 McGriff contends that he suffers from “Bipolar 2,” among other conditions; the prison medical staff initially diagnosed him with “unspecified depressive disorder,” but later abandoned that diagnosis. approximately 7:30 p.m. on August 7, McGriff was summoned to a “pill

line,” outside of his cell, to take his medication. McGriff objected because the medication made him drowsy and he wanted to take it in his cell at night. An argument ensued, and a nurse reported that McGriff threw the

medication at her; McGriff contends that he declined the medication in a respectful manner. Tress, who was not present, was notified of the nurse’s report and within minutes ordered that McGriff’s prescription be

“discontinued.” At a meeting on August 13, McGriff and Tress argued about the August 7 incident. Tress described McGriff as “agitated, argumentative, and demanding” and warned him against “inappropriate

behavior” toward staff. Ultimately, Tress found “no indication that [McGriff] needs to be [re]started on psychiatric medications [including Trazodone] at this time.”

Over the following years, McGriff made repeated, albeit inconsistent requests for his medication to be restored, arguing that he had suffered withdrawal symptoms and was still suffering symptoms of

anxiety and depression. Although he received some mental health care, largely in the form of instruction on “coping skills” and other non-medical “interventions,” the psychiatry staff did not evaluate McGriff for restoration of his medication, despite his repeated requests. The Court

denied both parties’ motions for summary judgment, finding that the evidence showed a genuine dispute of material fact as to whether Tress had cancelled the medication for a genuine medical reason, or as

punishment for McGriff’s “inappropriate behavior” towards staff. C. Discussion Tress seeks reconsideration on two grounds. First, she claims that the Court “misunderstood” McGriff to contend that he had previously

taken his medication at night in his own cell. Tress states that “[w]here the Court sources this argument . . . is unclear,” but those are the

allegations of McGriff’s complaint, which the Court summarized in the memorandum. (Doc. 101 at 2-3). To the extent Tress argues that McGriff’s allegation should not be considered because the “source” of his

argument is not in the evidentiary record3, the question is not whether

3 It was also apparent from Tress’s notes of her discussions with McGriff, among other evidence, that McGriff believed he should be permitted to take his medication at night in his cell because he had done so before. , , (Doc. 86 at 39 (“I have to take it to my cell and take it cause I pass out when I take it.”); 43 (“I take a large dose of medication at night. I’m not trying to take that much that early and then come down [to use the phone] . . . I’m not walking around here like a zombie.”)). the allegation itself is recited in the record but whether the evidence

supports the allegation. The memorandum explained how the medical notes plausibly supported McGriff’s allegations about the prior medication protocols. (Doc. 101 at 16-17).4 Moreover, the dispute

about the protocols prior to August 7 is not dispositive, because the ultimate question is whether Tress cancelled McGriff’s medication after August 7 for a non-medical reason.

Next, Tress objects that the Court misunderstood her rationale for cancelling the medication. In her statement of material facts, Tress described the rationale as follows:

McGriff’s medication was properly discontinued due to his attempt to circumvent the penological procedure for its administration, which required him to take any medication in view of nursing staff, the safety concerns related to potential medication hoarding by an inmate, and due to a lack of clinical indication that the medication was necessary for his treatment.

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Anthony McGriff v. Mrs. Cousins, Counsel Stack Legal Research, https://law.counselstack.com/opinion/anthony-mcgriff-v-mrs-cousins-pamd-2025.