Aycock v. Steincamp

CourtDistrict Court, M.D. Pennsylvania
DecidedJuly 25, 2025
Docket1:25-cv-01086
StatusUnknown

This text of Aycock v. Steincamp (Aycock v. Steincamp) 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
Aycock v. Steincamp, (M.D. Pa. 2025).

Opinion

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

RICHARD HUSTON AYCOCK, : Plaintiff : No. 1:25-cv-01086 : v. : (Judge Kane) : C.O. STEINCAMP, et al., : Defendants :

MEMORANDUM Currently before the Court are an application for leave to proceed in forma pauperis and complaint filed by pro se Plaintiff Richard Huston Aycock (“Aycock”). For the reasons set forth below, the Court will grant Aycock leave to proceed in forma pauperis and dismiss the complaint without prejudice to him filing an amended complaint. I. BACKGROUND Aycock, a convicted and sentenced state prisoner, commenced this action by filing a complaint that the Clerk of Court docketed on June 16, 2025. (Doc. No. 1.) Aycock did not, however, remit the filing fee or seek leave to proceed in forma pauperis when filing his complaint. As such, an Administrative Order issued requiring him to either remit the fee or apply for leave to proceed in forma pauperis within thirty (30) days. (Doc. No. 4.) Aycock’s application for leave to proceed in forma pauperis (“IFP Application”) and certified prisoner trust fund account statement were timely docketed on July 7, 2025. (Doc. Nos. 5, 6.) In his complaint, Aycock names the following correctional staff at Pennsylvania State Correctional Institution Benner Township (“SCI Benner Twp.”) as Defendants: (1) C.O. Steincamp (“Steincamp”); (2) C.O. Johnson (“Johnson”); (3) C.O. Husted (“Husted”); and (4) Sergeant Bloom (“Bloom”). (Doc. No. 1 at 1–3.) Aycock alleges that while incarcerated at SCI Benner Twp. on March 17–18, 2024, Defendants subjected him to “retaliation, physical and verbal abuse, mental and non-verbal abuse, [and] cruel and unusual punishment.”1 See (id. at 4). More specifically, Aycock avers that on March 17, 2024, Defendants Steincamp, Johnson, and Bloom told him that “two [correctional officers] was tooken [sic] to the hospital

because [Aycock] was playing, which [Aycock] dont [sic] have no knowledge of at all.” See (id.). Then, when he woke up in the morning on the following day, Defendants told him to “cover up [his] cell so [he] can be sprayed and killed” and informed Aycock if he did not do so he would be a “b---- [sic].” See (id.). Later, during Aycock’s morning meal, Husted told him to “watch what[ is] going to happen to [Aycock] for playing games and putting [Husted’s correctional officers] in the hospital.” See (id.). Eventually, Aycock was searched and transported to a surveillance cell before being transported to “cell JA-130,” where, unlike the other inmates in that area of the prison, he could not view the television. See (id.). While in his new cell, Aycock was “told to die or we are going to kill you because the [correctional officers] went to the hospital.”2 See (id.). Aycock

“was left to sleep with just [his] jumpsuit” and nothing else, and he had to “use [his] jumpsuit bottom cuff to wipe after using the bathroom.” See (id.). In addition, Aycock “was ignored and given nothing [until] the next day[,] which is on video footage after speaking with . . . Captain Stavola.” See (id.).

1 Aycock initially states that the events at issue occurred on March 18, 2024. (Id.) However, and as explained infra, Aycock seemingly describes events occurring over the course of two (2) days. (Id.) Thus, the Court construes Aycock’s factual allegations as occurring from March 17– 18, 2024.

2 It is unclear whether Aycock refers to Defendants when using the pronoun “we.” Based on these factual allegations, Aycock raises claims under 42 U.S.C. § 1983 against Defendants for violations of his right to be free from cruel and unusual punishment under the Eighth Amendment to the United States Constitution. (Id. at 5.) He appears to assert that Defendants violated his Eighth Amendment rights by failing to protect him from physical abuse

despite knowing that “there was a substantial risk that [he would] be harmed.” See (id.). Aycock also alleges that Defendants violated the Eighth Amendment by “respond[ing] and fail[ing] to protect him.” See (id.). He further alleges that Defendants violated his “right to be free from [d]iscrimination” and “right to be free from retaliation.” See (id.). Aycock indicates that he experienced “harm toward injury [sic] that was a torn rotator cuff in shoulder” and mental distress due to the verbally threatening “gestures” of “death or being killed by officers or correctional officers.” See (id.). For relief, Aycock seeks compensatory and punitive damages. (Id.) II. LEGAL STANDARDS A. Applications for Leave to Proceed in Forma Pauperis

Under 28 U.S.C. § 1915(a)(1), the Court may allow a plaintiff to commence a civil case “without prepayment of fees or security therefor,” if the plaintiff “submits an affidavit that includes a statement of all assets such prisoner possesses that the person is unable to pay such fees or give security therefor.”3 See id. This statute “is designed to ensure that indigent litigants have meaningful access to the federal courts.” Neitzke v. Williams, 490 U.S. 319, 324, 109 S.Ct. 1827, 104 L.Ed.2d 338 (1989). Specifically, Congress enacted the statute to ensure that administrative court costs and filing fees, both of which must be paid by everyone else who files a lawsuit, would not prevent indigent persons from pursuing meaningful litigation.

3 While the Court recognizes that Aycock is incarcerated, “[t]he reference to prisoners in § 1915(a)(1) appears to be a mistake. In forma pauperis status is afforded to all indigent persons, not just prisoners.” See Douris v. Middletown Twp., 293 F. App’x 130, 132 n.1 (3d Cir. 2008) (unpublished). [Deutsch v. United States, 67 F.3d 1080, 1084 (3d Cir. 1995)]. Toward this end, § 1915(a) allows a litigant to commence a civil or criminal action in federal court in forma pauperis by filing in good faith an affidavit stating, among other things, that [they are] unable to pay the costs of the lawsuit. Neitzke, 490 U.S. at 324, 109 S.Ct. 1827.

See Douris, 293 F. App’x at 131–32 (footnote omitted). A litigant can show that they are unable to pay the costs of the lawsuit “based on a showing of indigence.” See Deutsch, 67 F.3d at 1084 n.5. The Third Circuit Court of Appeals has not defined what it means to be indigent; nevertheless, “[a] plaintiff need not ‘be absolutely destitute to enjoy the benefit of the statute.’” See Mauro v. N.J. Supreme Ct. Case No. 56,900, 238 F. App’x 791, 793 (3d Cir. 2007) (unpublished) (quoting Adkins v. E.I. DuPont de Nemours & Co., 335 U.S. 331, 339 (1948)). Some district courts have explained that all a litigant needs to show is that because of their poverty, they cannot afford to pay for the costs of the litigation and provide themselves with the necessities of life. See, e.g., Rewolinski v. Morgan, 896 F. Supp. 879, 880 (E.D. Wis. 1995) (“An affidavit demonstrating that the petitioner cannot, because of his poverty, provide himself and any dependents with the necessities of life is sufficient.”); Jones v. State, 893 F. Supp. 643, 646 (E.D. Tex. 1995) (“An affidavit to proceed in forma pauperis is sufficient if it states that one cannot, because of poverty, afford to pay for the costs of litigation and still provide for him- or herself and any dependents.”). B. The Court’s Screening of the Complaint Under 28 U.S.C. §§ 1915A

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Aycock v. Steincamp, Counsel Stack Legal Research, https://law.counselstack.com/opinion/aycock-v-steincamp-pamd-2025.