COOK v. CARNEY

CourtDistrict Court, E.D. Pennsylvania
DecidedJune 26, 2024
Docket2:24-cv-00314
StatusUnknown

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

Bluebook
COOK v. CARNEY, (E.D. Pa. 2024).

Opinion

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

JAMAR M. COOK, : Plaintiff, : : v. : CIVIL ACTION NO. 24-CV-0314 : BLANCHE CARNEY, et al. : Defendants. :

MEMORANDUM YOUNGE, J. JUNE 26, 2024 Currently before the Court is an Amended Complaint filed by Plaintiff Jamar M. Cook, who is currently incarcerated at SCI Somerset. Cook raises several claims based on conditions to which he was subjected when he was a pretrial detainee incarcerated within the Philadelphia Prison System, with a focus on allegations that he was attacked twice by the same inmate. For the following reasons, the Court will dismiss the Amended Complaint in part. Cook will be given the option of filing a second amended complaint or proceeding at this time on his remaining, well-pled claims. I. FACTUAL ALLEGATIONS AND PROCEDURAL HISTORY Cook initiated this civil action by filing a Complaint pursuant to 42 U.S.C. § 1983 against Blanche Carney (the former Commissioner of the Philadelphia Prison System), Michell Farrell (identified in the Complaint as Warden of the Riverside Correctional Facility) and two John Doe Correctional Officers employed at the Riverside Correctional Facility (“RCF”). (Compl, ECF No. 2.) Cook alleged that the Defendants violated his constitutional rights by failing to take action to protect him from an attack by an inmate with whom he had a history, which occurred on January 20, 2022. (Id. at 2.) In an April 12, 2024 Order, the Court granted Cook leave to proceed in forma pauperis and directed Cook to complete paperwork (USM-285 forms) so that the Court could direct service of his Complaint by the United States Marshal Service. (ECF No. 13.) In doing so, the Court recognized that, although service could not be made upon the John Doe Correctional Officers without sufficient identifying information, the supervisory officials could be served in hopes of later identifying the staff who were more directly involved in the

events giving rise to Cook’s claims. (Id.) Cook returned with completed USM-285 forms for Defendants Carney and Farrell. (ECF No. 15.) At the same time, he filed an Amended Complaint, which added additional claims against additional defendants based on the January 20, 2022 incident at RCF and events pre- dating that incident when Cook was incarcerated at the Philadelphia Industrial Correctional Center (“PICC”). (Am. Compl., ECF No. 14.); see Fed. R. Civ. P. 15(a) (permitting a party to “amend its pleading once as a matter of course” in the early stages of a case). “[A]n amended pleading supersedes the original pleading and renders the original pleading a nullity.” Garrett v. Wexford Health, 938 F.3d 69, 82 (3d Cir. 2019). In other words, “the most recently filed

amended complaint becomes the operative pleading.” Id. This means Cook’s claims are now governed solely by the factual allegations in the Amended Complaint. In his Amended Complaint, Cook named the following Defendants in their individual and official capacities: (1) Carney; (2) Farrell, now identified as Warden of PICC during the relevant time period; (3) Cathy Talmadge, identified as Warden of RCF during the relevant time period; (4) C.O. 4 Dunkin, identified as a Hearing Examiner at PICC; (5) C.O. 1 MacCallister, identified as a Correctional Officer at PICC; (6) Corizon Health, the medical service provider for the Philadelphia Prison System during the relevant time period; (7) John Doe #1, a grievance officer at PICC; (8) John Doe #2, a grievance officer at RCF; (9) John Doe #3, a Correctional Officer at RCF; (10) John Doe # 4, another Correctional Officer at RCF; (11) John Doe #5 a Medical Supervisor at PICC; and (12) John Doe #6, a nurse at PICC. (Am. Compl. ¶¶ 4-16.) Cook alleges that, upon his admission to PICC as a pretrial detainee in October 2020, he observed that inmates at the facility could “easily breach their cell doors,” allowing them to “exit or enter their cells at will” and “violently assault other inmates.” (Id. ¶¶ 17-18.) He contends

that Carney and Farrell nevertheless “continued to house dangerous, violent offenders with non- violent offenders without fully addressing the ability and propensity for inmates to breach their cell doors to engage in assaults on inmates and staff.” (Id. ¶ 18.) On November 25, 2020, at least four inmates approached Cook and his cell mate in the presence of Defendant MacCallister. (Id. ¶ 19.) After the leader of the group of inmates “antagonized” Cook’s cell mate for having confronted an inmate who allegedly supplied the block with contraband, several of the inmates attacked Cook’s cell mate while one of the inmates attacked Cook. (Id. ¶ 20.) Cook alleges that several other inmates “managed to ‘pop out’” of their cells to join in the assault, such that ten or more inmates ultimately participated in the attack on Cook and his cell

mate. (Id. ¶¶ 21, 25.) Cook claims that MacCallister orchestrated the attack because the cell mate’s conduct was interfering with the ability of officers on the block (presumably including MacCallister) to profit from supplying contraband. (Id. ¶¶ 22-23.) Although MacCallister was allegedly present at the time of the attack, he “did nothing to prevent [it], such as order the inmates to disperse, deploy pepper-pray, and/or immediately radio for emergency response assistance.” (Id. ¶¶ 24-25.) Cook contends that McCallister finally called for assistance when “the confrontation that he orchestrated exceeded his control,” and that the incident resolved once additional officers responded. (Id. ¶¶ 25-26.) Thereafter, several inmates including Cook were “written up” and placed in the Restricted Housing Unit (“RHU”) pending a disciplinary hearing. (Id. ¶ 27.) Cook alleges that he never received notice of the disciplinary infractions with which he was charged and that, when he requested dismissal of the charges on that basis, Defendant Hearing Examiner Dunkin responded “you can take this forty-five days now or I can get you a copy [of the charges] . . . you

won’t like my mood . . . .” (Id. ¶¶ 27-29.) Cook accepted the discipline because he feared retaliation. (Id. ¶ 29.) He then appealed the sanction, filed a grievance, and took other actions in protest, including posting notices on his cell door directed to Carney and Farrell. (Id. ¶¶ 31-32.) Carney and Farrell, however, did not investigate Cook’s complaints or “take other corrective measures” even though, according to Cook, they “had direct knowledge” of them. (Id. ¶ 32.) While serving his disciplinary sentence in the RHU, Cook did not have access to phone calls or video visits and was placed in full restraints during recreation. (Id. ¶ 34.) Upon completion of his sentence, Cook remained in the RHU for administrative custody purposes until he was transferred to the RHU at the Philadelphia Detention Center in February 2021. (Id. ¶ 35.)

Cook claims that inmates were able to “easily breach their cell doors” at this facility as well, and that after he wrote to Carney, RHU officers “chain locked adjacent cell doors with one another” but removed the chains hours later because inmates complained. (Id. ¶¶ 36-37.) In June 2021, Cook was transferred to the RHU at RCF, where he contends inmates’ ability to “pop out” of their cells was “more rampant than he had ever witnessed at PICC and DC combined” because the locks could be manipulated with a thin piece of paper or plastic. (Id. ¶ 38.) Cook contends that Carney and Talmadge “were aware of this rampant and serious security breach which resulted in numerous violent assaults against inmates and even staff” but that “neither routine security/maintenance checks nor cell checks were conducted even immediately after a violent attack.” (Id.

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COOK v. CARNEY, Counsel Stack Legal Research, https://law.counselstack.com/opinion/cook-v-carney-paed-2024.