Mitchell v. Stavola

CourtDistrict Court, M.D. Pennsylvania
DecidedApril 15, 2025
Docket3:25-cv-00042
StatusUnknown

This text of Mitchell v. Stavola (Mitchell v. Stavola) 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
Mitchell v. Stavola, (M.D. Pa. 2025).

Opinion

UNITED STATES DISTRICT COURT MIDDLE DISTRICT OF PENNSYLVANIA

JUWAN MITCHELL,

Plaintiff, CIVIL ACTION NO. 3:25-cv-00042

v. (SAPORITO, J.)

J. STAVOLA, .,

Defendants.

MEMORANDUM Plaintiff Juwan Mitchell has filed a complaint (Doc. 16) alleging that she1 was attacked by several officers at SCI-Benner Township in June 2024. Pursuant to 28 U.S.C. § 1915, the Court will grant Mitchell leave to proceed and permit her to proceed on Eighth Amendment excessive force claims against four of the five defendants. The Court will deny Mitchell’s request for appointment of counsel without prejudice. I. BACKGROUND The Court received Mitchell’s signed complaint (Doc. 16) on April 1,

1 In another complaint recently filed in this district, Mitchell indicates that she is transgender and uses female pronouns. See Mitchell v. Confer et al., No. 3:25-cv-00216 (M. D. Pa. filed Feb. 4, 2025). 2024, after her previous submission (Doc. 1) was unsigned. In the

operative complaint, Mitchell alleges as follows: On June 18, 2024, she was placed in the Restricted Housing Unit at SCI-Benner Township, and later taken to a Psychiatric Observation Cell for evaluation. On that date,

defendants Capt. J. Stavola, CO1 McGary, CO1 Durst, and Lt. Tyson allegedly went to [Mitchell’s] cell and “said ‘when we come back we are going to bat2 the hell out of you.’” “Minutes later,” they allegedly “came

back and did that very thing.” The officers allegedly “slammed” Mitchell into “solid objects,” including a door post made of solid metal, and punched her several times. Mitchell also states that these officers “denied

[her] medical care, a grievance, hygiene products, and deliberately threatened [her] repeatedly.” Mitchell asserts Eighth Amendment claims, a First Amendment

claim based on the denial of access to a grievance process, and a Fourteenth Amendment equal protection claim. She asserts that she has suffered “physical, mental, [and] emotional injury,” and seeks unspecified

monetary relief.

2 Mitchell wrote the word “bat,” although it is possible from the context that she intended to write “beat.” See (Doc. 16 at 4). II. LEGAL STANDARDS Under 28 U.S.C. § 1915A, the Court is obligated to screen a civil

complaint in which a prisoner seeks redress from a governmental entity or an officer or employee of a governmental entity. 28 U.S.C. § 1915A(a); , 230 Fed. App’x 195, 197 (3d Cir. 2007). The

Court must dismiss the complaint if it is “frivolous” or “fails to state a claim upon which relief may be granted.” 28 U.S.C. § 1915A(b)(1). The Court has a similar obligation with respect to actions brought

and actions concerning prison conditions. 28 U.S.C. § 1915(e)(2)(B)(i); . § 1915(e)(2)(B)(ii); 42 U.S.C. § 1997e(c)(1);

, 568 F. Supp. 2d 579, 587–89 (W.D. Pa. 2008) (summarizing prisoner litigation screening procedures and standards).

The legal standard for dismissing a complaint for failure to state a claim under § 1915A(b)(1), § 1915(e)(2)(B)(ii), or § 1997e(c) is the same as that for dismissing a complaint pursuant to Rule 12(b)(6) of the Federal

Rules of Civil Procedure. , 481 Fed. App’x 705, 706 (3d Cir. 2012) (per curiam); , 696 F. Supp. 2d 454, 471 (M.D. Pa. 2010); , 568 F. Supp. 2d at 588. “Under Rule 12(b)(6), a motion to dismiss may be granted only if, accepting all well-pleaded

allegations in the complaint as true and viewing them in the light most favorable to the plaintiff, a court finds the plaintiff’s claims lack facial plausibility.” , 643 F.3d 77, 84 (3d Cir.

2011) (citing , 550 U.S. 544, 555–56 (2007)). In deciding the motion, the Court may consider the facts alleged on the face of the complaint, as well as “documents incorporated into the

complaint by reference, and matters of which a court may take judicial notice.” , 551 U.S. 308, 322 (2007). Although the Court must accept the fact allegations in the

complaint as true, it is not compelled to accept “unsupported conclusions and unwarranted inferences, or a legal conclusion couched as a factual allegation.” , 719 F.3d 160, 165 (3d Cir. 2013) (quoting

, 481 F.3d 187, 195 (3d Cir. 2007)). Mitchell seeks damages under 42 U.S.C. § 1983. Section 1983 provides in pertinent part:

Every person who, under color of any statute, ordinance, regulation, custom, or usage, of any State or Territory or the District of Columbia, subjects, or causes to be subjected, any citizen of the United States or other person within the jurisdiction thereof to the deprivation of any rights, privileges, or immunities secured by the Constitution and laws, shall be liable to the party injured in an action at law, suit in equity, or other proper proceeding for redress . . . . 42 U.S.C. § 1983. To establish a Section 1983 claim, a plaintiff must establish that the defendants, acting under color of state law, deprived the plaintiff of a right secured by the United States Constitution.

, 51 F.3d 1137, 1141 (3d Cir. 1995). To avoid dismissal for failure to state a claim, a civil rights complaint must state the conduct, time, place, and persons responsible for the alleged

violations. , 423 F.3d 347, 353 (3d Cir. 2005). Further, “[c]ivil rights claims cannot be premised on a theory of

. Rather, each named defendant must be shown . . . to have been personally involved in the events or occurrences which underlie a claim.” , 8 F. Supp. 3d 601, 613 (M.D. Pa. 2014)

(citation omitted). As explained by the Third Circuit Court of Appeals: A defendant in a civil rights action must have personal involvement in the alleged wrongs . . . . [P]ersonal involvement can be shown through allegations of personal direction or of actual knowledge and acquiescence. Allegations of participation or actual knowledge and acquiescence, however, must be made with appropriate particularity. , 845 F.2d 1195, 1207 (3d Cir. 1988). III. DISCUSSION The Eighth Amendment prohibits prison officials from

unnecessarily and wantonly inflicting pain in a manner that offends contemporary standards of decency. See Hudson v. McMillian, 503 U.S. 1, 8 (1992). A claim premised on excessive force against a prisoner turns

on whether the “force was applied in a good-faith effort to maintain or restore discipline, or maliciously and sadistically to cause harm.” Banks v.

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