TYLER v. LANCASTER COUNTY, PENNSYLVANIA

CourtDistrict Court, E.D. Pennsylvania
DecidedJanuary 26, 2022
Docket5:20-cv-02919
StatusUnknown

This text of TYLER v. LANCASTER COUNTY, PENNSYLVANIA (TYLER v. LANCASTER COUNTY, PENNSYLVANIA) 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
TYLER v. LANCASTER COUNTY, PENNSYLVANIA, (E.D. Pa. 2022).

Opinion

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

Plaintiff,

v. CIVIL ACTION NO. 20-2919 DAVID HINES and DAVID RAMOS,

Defendants.

MEMORANDUM OPINION Schmehl, J. s/JLS January 26, 2022

Plaintiff-inmate Dwayne Tyler, through counsel, alleges that he was “slammed” and “unmercifully beat[en]” by a correctional officer. However, video footage and plaintiff’s failure to present adequate evidence of any excessive force renders defendants entitled to Partial Summary Judgment. I. Factual Background

Plaintiff Dwayne Tyler was incarcerated at Lancaster County Prison at the time of the two incidents in question. On November 4, 2019, plaintiff noticed he had blood in his stool, in his bed sheets, and “all over the place” in his cell. (ECF #1, Complaint, at 4.) Plaintiff yelled for help and defendant Correction Officer David Hines came to his cell. Plaintiff placed his hands though the cell door slot so he could be handcuffed, then CO Hines escorted plaintiff and his cell mate to an area so that plaintiff could see a nurse. When CO Hines brought plaintiff to see the nurse, CO Hines allegedly “slammed him into a chair” in front of the nurse. (Id. at 5.) But this incident was captured on video surveillance. The video footage shows that when CO Hines brought plaintiff before the nurse, Hines grabbed a nearby chair, put it behind plaintiff, and tugged on plaintiff’s shirt to indicate to him to sit down. Plaintiff’s allegation that he was “slammed” is dispelled from the footage. After seeing the nurse, plaintiff and his cell mate were escorted back to their cell by CO Hines where plaintiff alleges he was “unmercifully beat[en]” once inside. (Id. at 6.) The video

footage does not show what occurred inside the cell, but the footage provides the following facts. Hines escorted plaintiff and his cell mate back to their cell while carrying two sets of bed sheets, one in each hand. Hines opened the cell door and all three men walk inside the cell although Hines should not have gone in the cell per prison protocols. According to plaintiff, when Hines went in the cell he “threw the sheets on the bed, and suddenly, without warning, and without provocation or cause, C/O Hines attacked Plaintiff and unmercifully beat him, and he punched Plaintiff two times in the middle of his chest, in the area of the ribs.” (Id. at 6.) CO Hines was inside plaintiff’s cell for less than three seconds. For plaintiff’s allegations to be true, Hines would have to walk into the cell, places the sheets down, beat plaintiff “unmercifully,” and then casually walk out of the cell, all within three seconds. Then after Hines

walked out of the cell, both inmates immediately and voluntarily placed their hands through the cell door slot to be uncuffed, Hines uncuffed them, and Hines casually walked away. Further, plaintiff provided zero evidence other than his above quoted allegation of this incident. Plaintiff even failed to provide testimony from the only nonparty eyewitness, plaintiff’s cell mate. Lastly, plaintiff sought medical attention eight times within the same month of the incident, but he never once complained of any pain or injuries relating to this alleged ‘attack.’ It was not until his ninth medical visit that he complained of injuries from this incident, but medical professionals did not provide him with any treatment for his alleged “injuries.” After a stipulation among counsel dismissing certain Counts, the remaining counts in this case are as follows: (1) excessive force against both defendants (Count I & II); assault and battery against both defendants (Count IV & VI); and intentional infliction of emotional distress against both defendants (Count V & VII). Presently, defendant David Hines moves for Partial

Summary Judgment on all Counts against him, and defendant David Ramos moves for Summary Judgement as to the IIED Count.1 II. Standard of Review Summary judgment is proper when there is no genuine dispute of material fact and the movant is entitled to a judgment as a matter of law. Fed.R.Civ.P. 56(a). A dispute as to a material fact is genuine if “the evidence is such that a reasonable jury could return a verdict for the nonmoving party.” Anderson v. Liberty Lobby, Inc., 477 U.S. 242, 255 (1986). On a motion for summary judgment, the court must consider the “underlying facts and all reasonable inferences therefrom in the light most favorable to the party opposing the motion.” Slagle v. Cnty. of Clarion, 435 F.3d 262, 264 (3d Cir. 2006) (citations omitted). If the movant carries its initial

burden of showing the basis of its motion, the burden shifts to the non-moving party to go beyond the pleadings and point to “specific facts showing that a genuine issue exists for trial.” Celotex Corp. v. Catrett, 477 U.S. 317, 323-24 (1986). In other words, the non-moving party “must present more than just bare assertions, conclusory allegations or suspicions to show the existence of a genuine issue.” Podobnik v. US. Postal Serv., 409 F.3d 584, 594 (3d Cir. 2005) (citation and internal quotation marks omitted). Summary judgment must be granted against a non-moving party who fails to sufficiently “establish the existence of an essential element of its

1 The remaining Counts after adjudication of this Motion for Partial Summary Judgment are those against defendant CO Ramos, Counts II & VI, for a separate alleged incident of excessive force and assault and battery occurring on February 21, 2020, that was not captured on video. case on which it bears the burden of proof at trial.” Blunt v. Lower Merion Sch. Dist., 767 F.3d 247, 265 (3d Cir. 2014). III. Analysis In each Count, plaintiff must prove some degree of force was committed against him.

Specifically, for the excessive force claim plaintiff must prove “whether force was applied in a good-faith effort to maintain or restore discipline, or maliciously and sadistically to cause harm.” Hudson v. McMillian, 503 U.S. 1, 6 (1992). For the assault claim, plaintiff must prove that the defendants placed him in a reasonable and immediate apprehension of harmful or offensive contact, and that act does cause such apprehension. Sides v. Cleland, 648 A.2d 793, 796 (Pa. Super. 1994). For the battery claim, plaintiff must prove an intentional offensive bodily contact. Renk v. City of Pittsburgh, 641 A.3d 289 (1994). For the IIED claim, plaintiff must prove, in part, extreme and outrageous conduct. Williams v. Guzzardi, 875 F.2d 46, 52 (3d Cir. 1989). Plaintiff failed to go beyond his allegations and point to specific facts showing a genuine issue for trial as to the November 4, 2019, incidents. See Celotex Corp., 477 U.S. at 323-24. The

video footage contradicts plaintiffs allegations that excessive force, assault, battery, and extreme and outrageous conduct occurred. See Scott v. Harris, 550 U.S. 372, 378-79 (2007) (discussing importance of video tape evidence).

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Related

Anderson v. Liberty Lobby, Inc.
477 U.S. 242 (Supreme Court, 1986)
Hudson v. McMillian
503 U.S. 1 (Supreme Court, 1992)
Scott v. Harris
550 U.S. 372 (Supreme Court, 2007)
Sides v. Cleland
648 A.2d 793 (Superior Court of Pennsylvania, 1994)
Blunt v. Lower Merion School District
767 F.3d 247 (Third Circuit, 2014)

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TYLER v. LANCASTER COUNTY, PENNSYLVANIA, Counsel Stack Legal Research, https://law.counselstack.com/opinion/tyler-v-lancaster-county-pennsylvania-paed-2022.