COTTLE v. PENNSYLVANIA DEPARTMENT OF CORRECTIONS

CourtDistrict Court, E.D. Pennsylvania
DecidedOctober 3, 2025
Docket2:24-cv-05160
StatusUnknown

This text of COTTLE v. PENNSYLVANIA DEPARTMENT OF CORRECTIONS (COTTLE v. PENNSYLVANIA DEPARTMENT OF CORRECTIONS) 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
COTTLE v. PENNSYLVANIA DEPARTMENT OF CORRECTIONS, (E.D. Pa. 2025).

Opinion

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

CHRISTOPHER COTTLE, : Plaintiff, : : v. : CIVIL ACTION NO. 24-CV-5160 : PENNSYLVANIA DEPARTMENT : OF CORRECTIONS, et al., : Defendants. :

MEMORANDUM

SÁNCHEZ, J. OCTOBER 3, 2025 Pro se Plaintiff Christopher Cottle, a prisoner currently housed at SCI Mahanoy, brings claims against the Pennsylvania Department of Corrections (“DOC”), five current or former DOC employees,1 and three John/Jane Doe Defendants arising out of his placement on a prolonged isolative status known as the “Restricted Release List.” Cottle raises constitutional claims pursuant to 42 U.S.C. § 1983, claims under Title II of the Americans with Disabilities Act (“ADA”), and state law claims for negligence, conspiracy and intentional infliction of emotional distress, seeking monetary damages and injunctive relief.2 Defendants have filed a partial motion to dismiss,

1 The individually named Defendants are Laurel Harry, John Wetzel, George Little, Michael Wenerowicz, Lucas Malishchak.

2 Cottle also seeks a declaration that his rights have been violated in the past. (ECF No. 1 (“Compl.”) at 2, 21.) Declaratory relief is unavailable to adjudicate past conduct, so Cottle’s request for this declaratory relief is improper. See Corliss v. O’Brien, 200 F. App’x 80, 84 (3d Cir. 2006) (per curiam) (“Declaratory judgment is inappropriate solely to adjudicate past conduct” and is also not “meant simply to proclaim that one party is liable to another.”); see also Andela v. Admin. Office of U.S. Courts, 569 F. App’x 80, 83 (3d Cir. 2014) (per curiam) (“Declaratory judgments are meant to define the legal rights and obligations of the parties in the anticipation of some future conduct.”). A declaratory judgment is also not “meant simply to proclaim that one party is liable to another.” Corliss, 200 F. App’x at 84 (per curiam); see also Taggart v. Saltz, No. 20-3574, 2021 WL 1191628, at *2 (3d Cir. Mar. 30, 2021) (per curiam) (“A declaratory judgment seeking dismissal of Cottle’s constitutional claims for money damages against the DOC and the individually named Defendants in their official capacities. They also seek dismissal of Cottle’s ADA claims and state law claims for negligence and conspiracy. The Court will grant the motion as to Cottle’s claims for money damages against the DOC and the individually named Defendants

in their official capacities, his ADA claims against the individual Defendants, his conspiracy claim, and his negligence claim except as to Defendant Malishchak. The motion will be denied as to Cottle’s negligence claim against Defendant Malishchak and as to Cottle’s ADA claim against the DOC. I. FACTUAL ALLEGATIONS3 Cottle alleges that he is currently housed under the DOC’s “most severe administrative and isolative ‘lock-down’ status known as the Restricted Release List” (hereinafter “RRL”). (Compl. at 5.) He asserts that he has been confined to the RRL for more than five years, and during this time, he has been subjected to “harsh; inhumane and unconstitutional conditions.” (Id. at 4-5.) By filing suit, Cottle seeks redress and to “shine light” on a “long-standing conspiracy by D.O.C.

officials and its mental health providers to undermine meaningful health care.” (Id. at 4.) Cottle avers that RRL status is “alleged to be for those inmates who present a clear and present threat to the orderly operations of a facility,” but has been misused by the DOC to “indefinitely confine particular inmates to harsh solitary conditions known to be detrimental to both mental and physical health over prolonged periods.” (Id. at 5.) (emphasis in original). He

is available to define the legal rights of the parties, not to adjudicate past conduct where there is no threat of continuing harm.”).

3 The factual allegations set forth in this Memorandum are taken from Cottle’s Complaint, which consists of twenty-one handwritten pages. (ECF No. 1.) The Court adopts the pagination supplied by the CM/ECF docketing system. Grammar, spelling, and punctuation errors in quotes from Cottle’s submissions are cleaned up where necessary. alleges that there are “no definitive criteria” that need to be met for either “initiation or removal of RRL status,” and even though RRL inmates are supposed to reviewed annually, the “annual review process” is “circumventive” and “perfunctory,” resulting in “unexplained and unwarranted continuances for years.” (Id. at 6.)

Cottle avers that inmates on the RRL are subject to harsher conditions of confinement than the general population. (Id. at 7.) For example, RRL inmates are allegedly denied contact visitation (Cottle alleges he has been denied physical contact for six years), the ability to marry, access to rehabilitative programming, exercise equipment, daily showers and adequate hygiene products, “meaningful interaction with staff and [other] inmates,” and the “ability to retain all of their legal material” and visit the law library on a regular basis. (Id. at 7-10.) Cottle also avers that mental health treatment for RRL inmates is limited to “brief cell side visits by unlicensed psych staff” even though a policy provides that inmates “are supposed to meet with psych staff out of cell at least every 30 days.” (Id. at 8.) Cottle asserts that “[a]ll named defendants are well aware that an abundance of literature

and psychiatric studies have found that prolonged segregation in solitary confinement has the potential to cause severe psychological harm,” but they continue “to promote prolonged segregation to indefinite solitary confinement status such as RRL” while “ignoring their obligation to ‘protect’ in the interest of promoting health and safety.” (Id. at 11.) Cottle contends that he has a history of mental illness that pre-dates his incarceration, yet he has not received any assistance from any DOC psychology or psychiatry personnel for his mental health disorders. (Id. at 12.) He avers that he has not been able to adjust to the “RRL status of prolonged confinement,” which has resulted in “instances of self harm as well as suicide attempts[] [and] feeling the overwhelming need to escape his conditions.” (Id. at 13.) He contends that Defendant Malishchak, who is identified as the “Psychology director” for the DOC, aided Defendants Harry, Wetzel, Little, Wenerowicz, and John/Jane Does 1-3 in “circumventing [Cottle’s] access to adequate mental health care; to justify his prolonged solitary confinement; while depriving him of the same level of care afforded to those confined to [general] population” who have the same or similar mental

health symptoms. (Id. at 13-14.) Based on these allegations, Cottle asserts constitutional claims of deliberate indifference and denial of adequate mental health care in violation of the Eighth Amendment and violations of his Fourteenth Amendment right to due process. (Id. at 15-16.) He also asserts violations of Title II of the ADA against all named Defendants and state law claims of negligence, conspiracy, and intentional infliction of emotional distress. (Id. at 17-19.) The DOC, Harry, Wetzel, Little, Wenerowicz, and Malishchak filed a Partial Motion to Dismiss Cottle’s Complaint pursuant to Federal Rule of Civil Procedure 12(b)(6) (hereinafter “Motion”). (ECF No. 26.) They seek dismissal of Cottle’s constitutional claims for money damages against the DOC and the individually named Defendants in their official capacities

pursuant to the Eleventh Amendment. They also seek dismissal of Cottle’s ADA claims against all Defendants as well as his state law claims of negligence and conspiracy based on sovereign immunity grounds.

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COTTLE v. PENNSYLVANIA DEPARTMENT OF CORRECTIONS, Counsel Stack Legal Research, https://law.counselstack.com/opinion/cottle-v-pennsylvania-department-of-corrections-paed-2025.