Ashley-Boyd v. Monroe County Correctional Facility

CourtDistrict Court, M.D. Pennsylvania
DecidedSeptember 11, 2024
Docket3:23-cv-01864
StatusUnknown

This text of Ashley-Boyd v. Monroe County Correctional Facility (Ashley-Boyd v. Monroe County Correctional Facility) 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
Ashley-Boyd v. Monroe County Correctional Facility, (M.D. Pa. 2024).

Opinion

| IN THE UNITED STATES DISTRICT COURT | FOR THE MIDDLE DISTRICT OF PENNSYLVANIA | JAHMIR ASHLEY-BOYD, : No. 3:23-CV-1864 | Plaintiff : : (Judge Munley) | V. :

| MONROE COUNTY CORRECTIONAL : FACILITY, et al., : | Defendants : | □□□□□□□□□□□□□□□□□□□□□□□□□□□□□ DEED LEDEIDEI EIDE LIDEDEIDE DELI DEDLIDDILnIIDEEEIII | MEMORANDUM

| Plaintiff Jahmir Ashley-Boyd initiated the above-captioned pro se civil | action under 42 U.S.C. § 1983,’ alleging constitutional violations by officials at Monroe County Correctional Facility (MCCF), in Stroudsburg, Pennsylvania. | Presently pending is Defendants’ motion for summary judgment under Federal | Rule of Civil Procedure 56. Ashley-Boyd has not opposed Defendants’ Rule 56 | motion in any way. The court, therefore, will grant Defendants’ motion.

| I. BACKGROUND In his complaint, Ashley-Boyd alleged that while he was housed at MCCF,

| the facility was experiencing plumbing issues that created unsanitary conditions of confinement from approximately October 6 to October 9, 2023. (Doc. 1 at 1,

| 1 Section 1983 creates a private cause of action to redress constitutional wrongs committed bi | state officials. The statute is not a source of substantive rights; it serves as a mechanism fo vindicating rights otherwise protected by federal law. See Gonzaga Univ. v. Doe, 536 U.S. 273 284-85 (2002).

3-4, 6-8). Specifically, Ashley-Boyd maintained that for four days, the toilets were not working in the area of the prison where he was confined, resulting in a back-up of human waste, foul smells, and no place for inmates to urinate or defecate. (Id. at 6-7). He alleged that, although he had informed numerous | prison Officials of these unsanitary and “inhumane living conditions,” nothing was | done to rectify them. (Id.) Ashley-Boyd named as defendants seven MCCF officials and the county correctional facility itself.2 (Id. at 1-2). He sought compensatory and punitive | damages, as well as various forms of injunctive relief. (Id. at 4, 9). Defendants answered Ashley-Boyd’s complaint. (Doc. 11). They now

move for summary judgment under Federal Rule of Civil Procedure 56. (Doc. 17). Ashley-Boyd has not opposed this motion in any way, and the time for doing so has passed. Defendants’ unopposed Rule 56 motion, therefore, is ripe for disposition. ll. STANDARD OF REVIEW “One of the principal purposes of the summary judgment rule is to isolate and dispose of factually unsupported claims or defenses.” Celotex Carp. v. Catrett, 477 U.S. 317, 323-24 (1986). Summary judgment is appropriate where

court subsequently dismissed MCCF pursuant to 28 U.S.C. § 1915A(b)(1). (See Doc. □□ | ,

| “the movant shows that there is no genuine dispute as to any material fact and

the movant is entitled to judgment as a matter of law.” FED. R. Civ. P. 56(a). Material facts are those “that could alter the outcome’ of the litigation, and “disputes are ‘genuine’ if evidence exists from which a rational person could

| conclude that the position of the person with the burden of proof on the disputed issue is correct.” EBC, Inc. v. Clark Bldg. Sys., Inc., 618 F.3d 253, 262 (3d Cir. 2010) (quoting Clark v. Modern Grp. Ltd., 9 F.3d 321, 326 (3d Cir. 1993)). | At the Rule 56 stage, the court’s function is not to “weigh the evidence and determine the truth of the matter” but rather “to determine whether there is a | genuine issue for trial.” Anderson v. Liberty Lobby, Inc., 477 U.S. 242, 249 (1986). The court must view the facts and evidence presented “in the light most favorable to the non-moving party” and must “draw all reasonable inferences in | that party’s favor.” Thomas v. Cumberland Cnty., 749 F.3d 217, 222 (3d Cir. 2014). This evidence, however, must be adequate—as a matter of law—to | sustain a judgment in favor of the nonmoving party on the claim or claims at issue. Liberty Lobby, 477 U.S. at 250-57; Matsushita Elec. Indus. Co. v. Zenith Radio Corp., 475 U.S. 574, 587-89 (1986). A “scintilla of evidence” supporting nonmovant’s position is insufficient; “there must be evidence on which the jury could reasonably find for the [nonmovant].” Daniels v. Sch. Dist. of Phila., 776 F.3d 181, 192 (3d Cir. 2015) (quoting Liberty Lobby, 477 U.S. at 252)

| (alteration in original). Succinctly stated, summary judgment is “put up or shut up time” for the nonmoving party. Daubert v. NRA Grp., LLC, 861 F.3d 382, 391 (3c Cir. 2017) (quoting Berckeley Inv. Grp. v. Colkitt, 455 F.3d 195, 201 (3d Cir. | 2006)). DISCUSSION? Defendants assert that during the period discussed in the complaint, | Ashley-Boyd was both a pretrial detainee and a convicted prisoner, as he pled | guilty to several offenses on October 13, 2023. (Doc. 18 Jf] 4-6). Defendants fai to mention that Ashley-Boyd was also sentenced that same day, which is equally material to his custody status. See Commonwealth v. Ashley-Boyd, No. CP-45- | CR-0003055-2021, at pp. 1, 29 (Pa. Ct. Com. Pl. Monroe Cnty.); Bistrian v. Levi, i 696 F.3d 352, 367 & n.6 (3d Cir. 2012) (“The Cruel and Unusual Punishments Clause . . . does not apply until an inmate has been both convicted of and | sentenced for his crimes.” (citing Graham v. Connor, 490 U.S. 386, 392 n.6 | (1989); Hubbard v. Taylor, 399 F.3d 150, 164 (3d Cir. 2005)), abrogated on other | grounds as stated by Mack v. Yost, 968 F.3d 311, 319 n.7 (3d Cir. 2020). jo |? Local Rule of Court 56.1 requires that a motion for summary judgment be supported “by 4 | separate, short, and concise statement of the material facts, in numbered paragraphs, as tc | which the moving party contends there is no genuine issue to be tried.” LOCAL RULE OF CouRT A party opposing a motion for summary judgment must file a separate statement of | material facts, responding to the numbered paragraphs set forth in the moving party’s □□□□□□□□□ | and identifying genuine issues to be tried. Id. Defendants properly filed their statement of facts, |(Doc. 18), but Ashley-Boyd failed to respond to that statement. Thus, the court will deem | admitted the facts in Defendants’ Rule 56.1 statement. See LOCAL RULE OF CourT 56.1. |

| Thus, from the time he entered MCCF until he was convicted and | sentenced on October 13, 2023, Ashley-Boyd was a pretrial detainee. Following | his guilty plea and sentencing on October 13, he was a convicted and sentenced state prisoner. Defendants contend that regardless of whether Ashley-Boyd was

a pretrial detainee or a convicted and sentenced prisoner, he cannot establish a | constitutional violation.

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Related

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Ashley-Boyd v. Monroe County Correctional Facility, Counsel Stack Legal Research, https://law.counselstack.com/opinion/ashley-boyd-v-monroe-county-correctional-facility-pamd-2024.