Jihaad Harrison v. Ms. Woodard, Ms. Stickney

CourtDistrict Court, E.D. Pennsylvania
DecidedJanuary 9, 2026
Docket2:25-cv-03500
StatusUnknown

This text of Jihaad Harrison v. Ms. Woodard, Ms. Stickney (Jihaad Harrison v. Ms. Woodard, Ms. Stickney) 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
Jihaad Harrison v. Ms. Woodard, Ms. Stickney, (E.D. Pa. 2026).

Opinion

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

JIHAAD HARRISON : CIVIL ACTION : v. : NO. 25-3500 : MS. WOODARD, MS. STICKNEY : :

MEMORANDUM KEARNEY, J. January 9, 2026 Incarcerated persons claiming mental health professionals working in their custodial facilities violated their constitutional rights may sue those health professionals by pleading facts showing the constitutional harm. But Congress requires the incarcerated person administratively exhaust their claims through the custodial facility’s published procedures before filing suit. The Pennsylvania Department of Corrections publishes and enforces a process to carefully review grievances from incarcerated persons. We today address an incarcerated person’s claim of harm arising from mental health professionals’ treatment in May 2025 violated their constitutional rights. The incarcerated person did not plead how they presented their claim to the facility. The mental health professionals move to dismiss arguing the incarcerated person did not meet Congress’s mandate by exhausting their administrative remedies inside the Facility but instead shortcut the process. We studied the pleaded pro se allegations and records. We agree the incarcerated person has not shown administrative exhaustion on the four grievances leading to their claims before us. We grant the mental health professionals’ motion to dismiss without prejudice to timely amend their allegations to plead how they administratively exhausted. I. Alleged pro se facts Jihaad Harrison entered SCI Phoenix on April 10, 2025 to serve part of their state sentence for violent crime convictions.1 Mx. Harrison attempted suicide on April 27, 2025 and received treatment at Jefferson University Hospital.2 They returned to SCI Phoenix on an unpleaded date. Mx. Harrison filed four grievances involving SCI Phoenix Mental Health Professionals Briana

Woodard and Christine Stickney between May 7 and May 22, 2025.3 The Mental Health Professionals claim Mx. Harrison did not exhaust internal administrative remedies through these four grievances. We evaluate each of those grievances in turn. May 7, 2025 Grievance No. 1146022. Mx. Harrison submitted Grievance No. 1146022 on May 7, 2025 concerning an interaction with Mental Health Professional Woodard earlier in the day.4 Mental Health Professional Woodard walked past Mx. Harrison’s cell and Mx. Harrison asked to speak to her “due to not getting along with” Mental Health Professional Stickney.5 They also asked Mental Health Professional Woodard to file an abuse complaint.6 Mental Health Professional Woodard “denied [Mx. Harrison]” and “left [them] in distress.”7 Mental Health Professional Woodard retaliated against Mx. Harrison for

“filing paperwork on psych dept” and violated Department of Corrections’ policies by refusing help.8 Mx. Harrison wrote “abuse complaint” at the top of the grievance form and staff “denied [Mx. Harrison] access to [the Department of Corrections’ Inmate Abuse] policy and forwarding [the] grievance to security.”9 May 12, 2025 Grievance No. 1146246. Mx. Harrison submitted Grievance No. 1146246 five days later on May 12, 2025 complaining about both Mental Health Professional Woodard and Mental Health Professional Stickney.10 They claimed Mental Health Professional Woodard denied Mx. Harrison medical treatment on May 7, May 8, and May 9, 2025 and when Mx. Harrison banged on their cell door for treatment, Mental Health Professional Woodard yelled, “[k]eep calling and Ima [sic] write you up.”11 Psychologist Woodard causes Mx. Harrison “extreme trauma and suicidal thoughts” and “leaves [them] in distress and targets [them].”12 Mx. Harrison spoke with Mental Health Professional Stickney on May 9, 2025 about Mental Health Professional Woodard’s conduct and Mental Health Professional Stickney stated, “I don’t [know] why she won’t help you but I told her

to speak to you.”13 Mx. Harrison wrote “abuse allegation not grievance” at the top of the grievance form and staff “denied [Mx. Harrison] access to [the Department of Corrections’ Inmate Abuse] policy and forwarding [the] grievance to security.”14 May 19, 2025 Grievance No. 1147398. Mx. Harrison submitted Grievance No. 1147398 seven days later on May 19, 2025 accusing Mental Health Professional Woodard of “refusing [them] treatment and dressing sexually.”15 Mental Health Professional Woodard “conducted a round by herself and didn’t walk by [Mx. Harrison’s] door” and “came around with a grey sundress that was cut open in the back exposing her body” earlier in the day.16 Mental Health Professional Woodard “ma[de Mx. Harrison] want to rape her brutal[l]y.”17 Mx. Harrison wrote “abuse complaint” at the top of the

grievance form and staff “completely rejected grievance for review and left [Mx. Harrison] in distress and with no rehabilitation.”18 May 22, 2025 Grievance No. 1148141. Mx. Harrison filed Grievance No. 1148141 three days later on May 22, 2025 complaining Mental Health Professional Woodard again denied them treatment.19 Mental Health Professional Woodard “conducted psych rounds by herself” on May 19, May 21, and May 22, 2025 and “denied [Mx. Harrison] all treatment on camera (blatantly ignoring [them]).”20 Mx. Harrison wrote “abuse” at the top of the grievance form and staff “denied [Mx. Harrison] access to [the Department of Corrections’ Inmate Abuse] policy and forwarding to security.”21 Mx. Harrison sues SCI Phoenix and state actors on July 7, 2025. Mx. Harrison sued SCI Phoenix and various facility officials and health care providers on July 7, 2025 asserting civil rights claims for deliberate indifference to their healthcare needs under

the Eighth Amendment and due process violations under the Fourteenth Amendment.22 We granted Mx. Harrison leave to proceed without paying the filing fees but requiring we meet Congress’s mandate of screening their allegations under section 1915A.23 We studied their allegations requiring we dismiss the due process claim as a matter of law.24 We dismissed all claims against SCI Phoenix with prejudice because SCI Phoenix is not a “person” amenable to suit under section 1983.25 We dismissed without prejudice the claims against all individual state actors except Mental Health Professionals Woodard and Stickney.26 II. Analysis Mental Health Professionals Woodard and Stickney move to dismiss arguing Mx. Harrison failed to exhaust their administrative remedies as to the four grievances as required by Congress

in the Prison Litigation Reform Act.27 Mx. Harrison opposes Mental Health Professionals Woodard and Stickney’s Motion only with respect to two grievances.28 Congress through the Prison Litigation Reform Act requires incarcerated persons to properly and completely exhaust administrative remedies before challenging their confinement conditions in federal court.29 We evaluate Mx. Harrison’s compliance with the Department of Corrections’ administrative regulations governing inmate grievances to determine whether they properly exhausted his claims.30 What constitutes “proper” exhaustion depends entirely on the facility’s established grievance policies.31 Our Court of Appeals instructs incarcerated persons need only exhaust the grievance procedures “available” to them; failure to exhaust is excused where grievance procedures, though “officially on the books,” are in reality “not capable of use to obtain relief.”32 “Failure to exhaust is an affirmative defense the defendant must plead and prove; it is not a pleading requirement for the [incarcerated ]plaintiff.”33 Our Court of Appeals further instructs “[a] plaintiff’s failure to exhaust his administrative remedies is an affirmative defense that, in an

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