Rodriguez v. United States

CourtDistrict Court, M.D. Pennsylvania
DecidedSeptember 27, 2024
Docket4:22-cv-01735
StatusUnknown

This text of Rodriguez v. United States (Rodriguez v. United States) 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
Rodriguez v. United States, (M.D. Pa. 2024).

Opinion

UNITED STATES DISTRICT COURT MIDDLE DISTRICT OF PENNSYLVANIA JUAN RODRIGUEZ, ) CIVIL ACTION NO. 4:22-CV-1735 Plaintiff ) ) v. ) ) (ARBUCKLE, M.J.) UNITED STATES OF AMERICA, ) Defendant ) ) MEMORANDUM OPINION I. INTRODUCTION On March 13, 2020, former inmate Juan Rodriguez (“Plaintiff”) fractured his left ankle attempting to deliver food trays to the Schuylkill Federal Correction Institution (“FCI Schuylkill”) Special Housing Unit (“SHU”). Plaintiff initiated this lawsuit under the Federal Tort Claims Act (“FTCA”) alleging that his injury was the result of a prison employee’s negligence. Defendant, however, argues that the work- related injury Plaintiff sustained is subject to the Inmate Accident Compensation Act (“IACA”), and therefore cannot proceed under the FTCA. Currently before the Court is Defendant’s Motion to Dismiss Plaintiff’s Complaint pursuant to Rule 12(b)(1) of the Federal Rules of Civil Procedure because the Court does not have subject-matter jurisdiction over Plaintiff’s FTCA claim. For

the reasons explained herein, Defendant’s Motion will be granted, but Plaintiff will be given leave to file a second amended complaint. II. BACKGROUND AND PROCEDURAL HISTORY In March 2020, Plaintiff was an inmate in federal custody at FCI Schuylkill.

His “regular work assignment” at the time was as a “PM Cook” in the institution’s Food Services Department. He worked Wednesday through Sunday, and his days off were Monday and Tuesday.

On March 13, 2020, two- and one-half weeks before his injury, Plaintiff signed an “Initial Job Orientation and Safety Training” handout on pages 1 and 10. (Doc. 21-1, pp. 7-16). Page 5 of that handout states as follows: Work Related Injuries: If you are injured while performing your work assignment, no matter how minor it may seem, report the injury to your work supervisor. Failure to report a work injury within a maximum of 48 hours may result in the forfeiture of lost time wages and/or inmate accident compensation. If you suffer a work injury, and feel your injury resulted in some degree of physical impairment, you may file a claim for Inmate Accident Compensation. It is your responsibility to contact the Environmental and Safety Compliance Office no later than 45 days before your release if you intend to file a claim for disability related to a work injury. (Doc. 21-1, p. 11). On March 31, 2020, a Tuesday, Plaintiff was “made” to work in the morning as an AM Cook on his day off. He spent the first several hours of his shift preparing food, a task he customarily performed during his regularly scheduled shifts. Between 10:30 a.m. and 11:00 a.m., a corrections officer “ordered” Plaintiff to perform a task he was unfamiliar with in a manner that Plaintiff felt was not safe. He was ordered to transport food trays to the special housing unit using a cart. Plaintiff alleges that the cart he was ordered to use was not a food cart and had defective wheels. (Doc. 15, ¶¶ 14-28). Plaintiff followed the order, fearing that if he did not, he would be

punished. (Doc. 15, ¶¶ 37-38). Unfortunately, he encountered a pothole along his route. (Doc. 15, ¶¶ 42-45). The food-laden cart veered into the pothole and tipped over. Id. The cart landed on Plaintiff, fracturing his left ankle. (Doc. 17-3, p. 5)

(noting a “palpable fx left medial about 3 cm superior to malleolus”). Plaintiff was given a tetanus shot, the abrasions on his foot and ankle were cleaned and dressed, and his fractured ankle was placed in a CAM boot. Id. Plaintiff’s supervisor completed a BP-140, Injury Report, which Plaintiff

signed. (Doc. 17-3, pp. 6-7). The report was reviewed by the Institutional Safety Manager. Id. On May 8, 2020, the institution’s Safety Committee expressed the opinion that Plaintiff’s injury was work-related. Id. Plaintiff was, at some point,

given a copy of that form. (Doc. 26, pp. 6-7). Plaintiff’s copy of the form did not advise him of his rights under the IACA and did not include the Safety Committee’s opinion as to whether his injury was work-related. Id. It appears Plaintiff was unable to work as a cook in the food services

department following his injury.1 Plaintiff never filed a claim for accident

1 (Doc. 17-3, p. 8) (noting Plaintiff lost work time from March 31, 2020 to May 1, 2020); (Doc. 17-3, p. 8) (recommending that Plaintiff be removed from food service on June 11, 2020); (Doc. 21-1, p. 6) (noting Plaintiff was reassigned to work in general maintenance on June 16, 2020). compensation. (Doc. 17-4, p. 2). On December 7, 2020, Plaintiff was released from prison. (Doc. 21-1, p. 3).

On November 18, 2021, Plaintiff filed an administrative claim to recover for his March 31, 2020 injury. (Doc. 16, ¶ 7). On May 3, 2022, Plaintiff’s claim was denied. (Doc. 15, ¶ 8).

In November 2022, Plaintiff initiated this lawsuit. (Doc. 1). In May 2023, he amended his complaint. (Doc. 15). In his Amended Complaint, Plaintiff asserts a single claim against the United States of America under the FTCA alleging that Defendant’s negligence caused a physical injury to his left ankle, and that this injury

has resulted in: Plaintiff suffering great pain in mind and body, and loss of enjoyment of life and business and[,] . . . loss of earning capacity and other expenses. (Doc. 15, ¶ 64). Defendant filed a factual challenge to this Court’s subject-matter jurisdiction under 12(b)(1) and seeks summary judgment in the alternative. Plaintiff opposes its motion. Although the parties dispute whether Plaintiff’s injury is subject to the

IACA as a matter of law, they do not appear to dispute the material facts relating to the time and place the injury occurred, or the way Plaintiff was injured. Defendant’s Motion is fully briefed. In the absence of any material dispute of fact, we will proceed without a hearing. Therefore, this matter is now ready to

decide. III. LEGAL STANDARDS Having reviewed the background and procedural history of this case, it is

helpful to review the applicable legal standard for motions brought under Rule 12(b)(1) of the Federal Rules of Civil Procedure, and the standards for FTCA and IACA claims. A. FED. R. CIV. P. 12(B)(1): MOTION TO DISMISS FOR LACK OF JURISDICTION Rule 12(b)(1) of the Federal Rules of Civil Procedure permits a party to

challenge a complaint for lack of subject-matter jurisdiction in lieu of filing an answer. Defendant’s Motion presents a factual challenge to the Court’s subject- matter jurisdiction. A factual challenge “attacks the factual allegations underlying the complaint’s assertion of jurisdiction” by presenting competing facts.2 When

considering a factual challenge to its subject matter jurisdiction, a court is permitted to “weigh and consider evidence outside the pleadings.”3

2 Davis v. Wells Fargo, 824 F.3d 333, 346 (3d Cir. 2016) (quoting Const. Party of Pa. v. Aichele, 757 F.3d 347, 358 (3d Cir. 2014)). 3 Id.; see also Mortensen v. First Fed. Sav. & Loan Ass’n, 549 F.2d 884, 891 (3d Cir. 1977). Once jurisdiction is challenged, a plaintiff has the burden to prove jurisdiction exists by a preponderance of the evidence.4 When reviewing a defendant’s factual

Free access — add to your briefcase to read the full text and ask questions with AI

Related

Ellis v. Federal Prison Indus
95 F.3d 54 (Fifth Circuit, 1996)
United States v. Demko
385 U.S. 149 (Supreme Court, 1966)
Lomando v. United States
667 F.3d 363 (Third Circuit, 2011)
Cna v. United States
535 F.3d 132 (Third Circuit, 2008)
Davis v. United States
415 F. Supp. 1086 (D. Kansas, 1976)
Constitution Party of Pennsylv v. Carol Aichele
757 F.3d 347 (Third Circuit, 2014)
Lincoln Benefit Life Co. v. AEI Life, LLC
800 F.3d 99 (Third Circuit, 2015)
Cooleen v. Lamanna
248 F. App'x 357 (Third Circuit, 2007)
Davis v. Wells Fargo, U.S.
824 F.3d 333 (Third Circuit, 2016)
Mortensen v. First Federal Savings & Loan Ass'n
549 F.2d 884 (Third Circuit, 1977)

Cite This Page — Counsel Stack

Bluebook (online)
Rodriguez v. United States, Counsel Stack Legal Research, https://law.counselstack.com/opinion/rodriguez-v-united-states-pamd-2024.