WASHINGTON v. MONTGOMERY COUNTY CORRECTIONAL FACILITY

CourtDistrict Court, E.D. Pennsylvania
DecidedAugust 11, 2025
Docket2:25-cv-02967
StatusUnknown

This text of WASHINGTON v. MONTGOMERY COUNTY CORRECTIONAL FACILITY (WASHINGTON v. MONTGOMERY COUNTY CORRECTIONAL FACILITY) 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
WASHINGTON v. MONTGOMERY COUNTY CORRECTIONAL FACILITY, (E.D. Pa. 2025).

Opinion

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

KYLEEM KELLIE WASHINGTON, : Plaintiff, : : v. : CIVIL ACTION NO. 25-CV-2967 : MONTGOMERY COUNTY : CORRECTIONAL FACILITY, : Defendant. :

MEMORANDUM BEETLESTONE, C.J. AUGUST 11, 2025 Pro se incarcerated Plaintiff Kyleem Kellie Washington filed this civil action against the Montgomery County Correctional Facility (MCCF) and has requested leave to proceed in forma pauperis. For the following reasons, the Court will grant Washington leave to proceed in forma pauperis and dismiss his Complaint in part with prejudice and in part without prejudice. I. FACTUAL ALLEGATIONS1 Washington was an inmate at MCCF when he allegedly suffered an injury from a fall. (Compl. at 4.) On March 27, 2025, Washington was walking down “J-Pod stairwell 5” and slipped and fell on wet steps. (Id. at 4-5.) He asserts that he “had no knowledge of [the steps] being wet” because no cautionary sign warning of the wet steps had been posted. (Id. at 5.) He claims that another inmate witnessed his fall, and that the stairwell has a camera. (Id.) He allegedly sustained a back and neck injury. (Id.) A corrections officer informed a supervisor, who apparently contacted the medical staff. (Id. at 7.) After some delay, the medical staff

1 The factual allegations are taken from Washington’s Complaint (“Compl.”). (ECF No. 2.) The Court adopts the pagination supplied by the CM/ECF docketing system. examined him on the scene and ordered an X-ray.2 (Id. at 5, 7.) Washington eventually received muscle relaxants to relieve his pain. (Id. at 5.) The thin and outdated bedding also contributed to the pain from his injuries. (Id. at 7.) Officials at the MCCF withheld Washington’s X-rays from him. (Id.) As a result of these events, he alleges claims pursuant to 42 U.S.C. § 1983 against

MCCF and seeks $50,000 in damages. (Id.) II. STANDARD OF REVIEW The Court will grant Washington leave to proceed in forma pauperis because it appears that he is incapable of paying the fees to commence this civil action.3 Accordingly, 28 U.S.C. § 1915(e)(2)(B) requires the Court to dismiss the complaint if, among other things, it fails to state a claim. Whether a complaint fails to state a claim under § 1915(e)(2)(B)(ii) is governed by the same standard applicable to motions to dismiss under Federal Rule of Civil Procedure 12(b)(6),

2 It is unclear whether Washington intended to assert claims about his medical care or merely provided these allegations as background information to his other claims. Even had he intended to do so, his complaints about his medical treatment do not allege plausible constitutional claims. He has not identified a defendant who was personally involved in denying him medical care nor did he allege facts indicating that particular prison officials were deliberately indifferent to his serious medical needs. See Farmer v. Brennan, 511 U.S. 825, 835 (1994). A prison official is not deliberately indifferent “unless the official knows of and disregards an excessive risk to inmate health or safety; the official must both be aware of facts from which the inference could be drawn that a substantial risk of serious harm exists, and he must also draw the inference.” Id. at 837. “A medical need is serious, . . . if it is one that has been diagnosed by a physician as requiring treatment or one that is so obvious that a lay person would easily recognize the necessity for a doctor’s attention.” Monmouth Cnty. Corr. Institutional Inmates v. Lanzaro, 834 F.2d 326, 347 (3d Cir. 1987) (internal quotations omitted). Deliberate indifference is properly alleged “where the prison official (1) knows of a prisoner’s need for medical treatment but intentionally refuses to provide it; (2) delays necessary medical treatment based on a non- medical reason; or (3) prevents a prisoner from receiving needed or recommended medical treatment.” Rouse v. Plantier, 182 F.3d 192, 197 (3d Cir. 1999). A serious medical need exists where “failure to treat can be expected to lead to substantial and unnecessary suffering.” Colburn v. Upper Darby Twp., 946 F.2d 1017, 1023 (3d Cir. 1991).

3 Because Washington is a prisoner, he must still pay the $350 filing fee for this case in installments as required by the Prison Litigation Reform Act. see Tourscher v. McCullough, 184 F.3d 236, 240 (3d Cir. 1999), which requires the Court to determine whether the complaint contains “sufficient factual matter, accepted as true, to state a claim to relief that is plausible on its face.” Ashcroft v. Iqbal, 556 U.S. 662, 678 (2009) (quotations omitted). When the litigation is in this early stage, the Court accepts the facts alleged

in the pro se complaint as true, draws all reasonable inferences in the plaintiff’s favor, and considers whether the complaint, liberally construed, contains facts sufficient to state a plausible claim. Shorter v. United States, 12 F.4th 366, 374 (3d Cir. 2021), abrogation on other grounds recognized by Fisher v. Hollingsworth, 115 F.4th 197 (3d Cir. 2024). Conclusory allegations do not suffice. Iqbal, 556 U.S. at 678. As Washington is proceeding pro se, the Court construes his allegations liberally. Vogt v. Wetzel, 8 F.4th 182, 185 (3d Cir. 2021) (citing Mala v. Crown Bay Marina, Inc., 704 F.3d 239, 244-45 (3d Cir. 2013)). Furthermore, the Court must dismiss the Complaint if it lacks subject matter jurisdiction. Fed. R. Civ. P. 12(h)(3) (“If the court determines at any time that it lacks subject-matter jurisdiction, the court must dismiss the action.”); Grp. Against Smog and Pollution, Inc. v.

Shenango, Inc., 810 F.3d 116, 122 n.6 (3d Cir. 2016) (explaining that “an objection to subject matter jurisdiction may be raised at any time [and] a court may raise jurisdictional issues sua sponte”). A plaintiff commencing an action in federal court bears the burden of establishing federal jurisdiction. See Lincoln Ben. Life Co. v. AEI Life, LLC, 800 F.3d 99, 105 (3d Cir. 2015) (“The burden of establishing federal jurisdiction rests with the party asserting its existence.”). “Jurisdictional [issues] . . . may be raised at any time and courts have a duty to consider them sua sponte.” Wilkins v. United States, 598 U.S. 152, 157 (2023) (internal quotations omitted). III. DISCUSSION A. Claims Pursuant to § 1983 Against the MCCF The vehicle by which federal constitutional claims may be brought in federal court is an action under 42 U.S.C. § 1983. “To state a claim under § 1983, a plaintiff must allege the

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Bluebook (online)
WASHINGTON v. MONTGOMERY COUNTY CORRECTIONAL FACILITY, Counsel Stack Legal Research, https://law.counselstack.com/opinion/washington-v-montgomery-county-correctional-facility-paed-2025.