Tindell v. Dept. of Corr., PICS Case No. 14-0475 (Pa. Commw. March 24, 2014) Colins, J. (20 pages).

COMMONWEALTH COURT

The Legal Intelligencer

CONSTITUTIONAL LAW

Cruel and Unusual Punishment • Prisoners' Health • Prison Conditions

Tindell v. Dept. of Corr., PICS Case No. 14-0475 (Pa. Commw. March 24, 2014) Colins, J. (20 pages).

Where prisoners brought an Eighth Amendment claim challenging the adequacy of the conditions of their imprisonment, the only relief that could be sought was equitable relief, and because a mandamus action can only compel a ministerial act instead of evaluating the quality of an official's efforts, the prisoners failed to state a claim for mandamus. Granted and dismissed.

Petitioners Archie Tindell and James Wright, prisoners in the Pennsylvania Department of Corrections system, brought a petition for review in the nature of mandamus, alleging conditions in their Restricted Housing Unit that violated DOC regulations and policies, and that as a result of corrections officers' deliberate indifference to petitioners' serious medical needs, they were denied their constitutional right to be free from the infliction of cruel and unusual punishment guaranteed under the Eighth and Fourteenth Amendments to the U.S. Constitution. Petitioners also alleged that the conditions of the RHU denied basic human necessities; specifically, (1) that the RHU was excessively cold; (2) that the ventilation system spread fecal dust which could cause respiratory infections and was so loud as to prevent sleep; (3) that the RHU included significant social isolation and reduced environmental stimulation that could lead to mental illness; (4) that corrections officers used racism, intimidation and retaliation as part of a behavior modification regime; (5) that the food lacked nutritional value and was served after it should have been discarded; and (6) that prisoners had not been given adequate clothing, linens and footwear.

Respondents argued that petitioners had not stated a clear legal right to mandamus, and that an alternative remedy existed in the form of a civil rights action under 42 U.S.C. §1983.

The court noted that in order for an Eighth Amendment claim for deliberate indifference of medical needs to succeed, a petitioner had to establish a sufficiently serious medical need, including a need that may result from a condition of confinement that was very likely to pose an unreasonable risk of serious damage to future health, and establish the deliberate indifference of prison officials by showing that the officials knew of and disregarded an excessive risk to prisoner health, or that officials knew of facts from which an inference of excessive risk could be drawn and the officials drew that inference. The court found that petitioners failed to allege specific acts taken or omitted by prison officials in support of the deliberate indifference element and failed to identify harm suffered by petitioners.

The court further noted that while the prohibition against cruel and unusual punishment did not require comfortable prisons, it did require prisons to provide the minimal measure of necessities, including food, clothing, shelter, sanitation, medical care and personal safety. However, the court found that petitioners did not allege that they were denied these necessities, only that they were inadequate. The court held that an Eighth Amendment claim based on the adequacy of prison conditions was not the proper subject of a mandamus action, as a mandamus action could only compel prison officials to provide necessities but could not evaluate the quality of those necessities or order officials to provide those necessities in a particular way.

The court held that because petitioners were not seeking to enforce clearly established rights, but instead were seeking to establish what their rights were and obtain appropriate relief, petitioners had not stated a claim for mandamus.

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