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Case Name Shoatz v. Wetzel PC-PA-0039
Docket / Court 2:13-cv-00657-CRE ( W.D. Pa. )
State/Territory Pennsylvania
Case Type(s) Prison Conditions
Special Collection Solitary confinement
Case Summary
On May 8, 2013, a prisoner in Pennsylvania's state prisons filed this lawsuit in the U.S. District Court for the Western District of Pennsylvania. The plaintiff sued the Secretary of the Pennsylvania Department of Corrections as well as the superintendents of SCI-Greene and SCI-Mahanoy under 42 U.S. ... read more >
On May 8, 2013, a prisoner in Pennsylvania's state prisons filed this lawsuit in the U.S. District Court for the Western District of Pennsylvania. The plaintiff sued the Secretary of the Pennsylvania Department of Corrections as well as the superintendents of SCI-Greene and SCI-Mahanoy under 42 U.S.C. § 1983. Represented by private counsel, the plaintiff asked the court for both injunctive relief and damages, alleging that the defendants violated the plaintiff's Eighth and Fourteenth Amendment rights by keeping him in solitary confinement for 22 consecutive years.

The parties initiated discovery. On July 3, 2013, the defendants filed a motion to dismiss. After numerous extensions for replies, the parties set a date for mediation on October 30, 2013. The mediation was unsuccessful.

On January 27, 2014, Magistrate Judge Cynthia Reed Eddy denied defendants' motion to dismiss. Judge Eddy held that the plaintiff's complaint alleged sufficiently plausible facts on both his Eighth Amendment and Fourteenth Amendment claims. Specifically, the plaintiff plausibly asserted that the conditions of his confinement caused severe physical and mental distress and that the defendants not only knew about his suffering, but were deliberately indifferent to it. His Fourteenth Amendment claim was not barred by claim preclusion from prior litigation challenging his solitary confinement because of new circumstances and the extended duration of the confinement. Further, the administration violated his procedural due process rights by failing to give him adequate information for why he was being kept in solitary confinement. 2014 WL 294988 (W.D. Pa. Jan. 27, 2014).

The parties continued discovery for the next ten months. On November 21, 2014, the plaintiff filed an amended complaint.

On July 15, 2015, the plaintiff filed a motion for summary judgment. On August 6, 2015, the defendants filed their own motion for summary judgment. After numerous extensions for responses to the summary judgment motions, Judge Eddy issued her opinion on February 12, 2016, denying both motions. She held that there were material issues of fact on both the Eighth and Fourteenth Amendment claims to warrant a jury trial. 2016 WL 595337 (Feb. 12, 2016).

On May 10, 2015, the parties engaged in successful mediation and reached a settlement-in-principle.The Department of Corrections agreed to not place the plaintiff back in solitary confinement due to his prior disciplinary record or activities, to provide a single cell (and not have to share it for the rest of his life), to provide him with full mental health evaluation, and pay a monetary settlement. On July 25, 2016, Judge Eddy approved the stipulation of voluntary dismissal and the case was dismissed with prejudice. (https://abolitionistlawcenter.org/2016/07/11/media-release-settlement-reached-in-shoatz-v-wetzel/)

During the period of mediation, the Department of Justice announced that it was closing an investigation against the Pennsylvania Department of Corrections for its use of solitary confinement. The PDOC stipulated that it would ensure that prisoners are not sent to solitary confinement, expand mental health classification processes and streamline mental health care delivery, provide more mental health training to staff, and offer more out-of-cell activities for prisoners in solitary confinement. The DOJ letter also indicated that PDOC would commit to ensuring that all inmates with a serious mental health condition either present or in the past would be diverted to treatment units, reduce use of restraints, improve mental health staffing and recordkeeping, expand commitment units, better identify prisoners with intellectual disabilities, and improve quality assurance processes. (DOJ letter)

No further activity has appeared on the docket. Presumably the case is closed.

Craig Streit - 09/25/2016


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Issues and Causes of Action
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Issues
Constitutional Clause
Cruel and Unusual Punishment
Defendant-type
Corrections
General
Administrative segregation
Conditions of confinement
Disciplinary segregation
Solitary confinement/Supermax (conditions or process)
Medical/Mental Health
Mental health care, general
Untreated pain
Plaintiff Type
Private Plaintiff
Type of Facility
Government-run
Causes of Action 42 U.S.C. § 1983
Defendant(s) Pennsylvania Department of Corrections
Pennsylvania Department of Corrections
Pennsylvania Department of Corrections
Plaintiff Description A Pennsylvania state prisoner who alleges that his 22 years in solitary confinement violated his 8th and 14th Amendment rights.
Indexed Lawyer Organizations None on record
Class action status sought No
Class action status granted Moot
Prevailing Party Mixed
Public Int. Lawyer Yes
Nature of Relief Injunction / Injunctive-like Settlement
Source of Relief Settlement
Form of Settlement Private Settlement Agreement
Voluntary Dismissal
Order Duration not on record
Case Closing Year 2016
Case Ongoing No
Additional Resources
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Case Studies Civil Rights Injunctions Over Time: A Case Study of Jail and Prison Court Orders
N.Y.U. Law Review
By: Margo Schlanger (Washington University)
Citation: 81 N.Y.U. L. Rev. 550 (2006)
[ Detail ] [ PDF ] [ External Link ]

  Judicial Policy Making and the Modern State: How the Courts Reformed America's Prisons
By: Malcolm M. Feeley & Edward Rubin (UC Berkeley Boalt Hall School of Law & Vanderbilt School of Law Faculty)
Citation: (1998)
[ Detail ]

Docket(s)
2:13-cv-00657-CRE (W.D. Pa.) 07/25/2016
PC-PA-0039-9000.pdf | Detail
PACER [Public Access to Court Electronic Records]
General Documents
Complaint 05/08/2013
PC-PA-0039-0003.pdf | Detail
Document Source: PACER [Public Access to Court Electronic Records]
Memorandum Opinion and Order 01/27/2014 (2014 U.S.Dist.LEXIS 9386) (W.D. Pa.)
PC-PA-0039-0005.pdf | LEXIS | Detail
Document Source: PACER [Public Access to Court Electronic Records]
First Amended Complaint 11/21/2014
PC-PA-0039-0006.pdf | Detail
Document Source: PACER [Public Access to Court Electronic Records]
Memorandum Opinion and Order 02/12/2016 (2016 WL 595337 / 2016 U.S.Dist.LEXIS 17515) (W.D. Pa.)
PC-PA-0039-0004.pdf | WESTLAW| LEXIS | Detail
Document Source: PACER [Public Access to Court Electronic Records]
Justice Department Closes Investigation After Pennsylvania Department of Corrections Takes Significant Steps to Reform its Use of Solitary Confinement 04/14/2016
PC-PA-0039-0001.pdf | Detail
Closing Letter Re: Investigation of the Pennsylvania Department of Corrections' Use of Solitary Confinement on Prisoners with Serious Mental Illness and/or Intellectual Disabilities 04/14/2016
PC-PA-0039-0002.pdf | Detail
Stipulation of Voluntary Dismissal 07/25/2016 (W.D. Pa.)
PC-PA-0039-0007.pdf | Detail
Document Source: PACER [Public Access to Court Electronic Records]
Judges Eddy, Cynthia Reed Court not on record [Magistrate]
PC-PA-0039-0004 | PC-PA-0039-0005 | PC-PA-0039-0007 | PC-PA-0039-9000
Monitors/Masters None on record
Plaintiff's Lawyers Burt, Stefanie Lepore (Pennsylvania)
PC-PA-0039-0006 | PC-PA-0039-0007 | PC-PA-0039-9000
Engel, Harold (Maryland)
PC-PA-0039-9000
Etter, Richard L (Pennsylvania)
PC-PA-0039-0003 | PC-PA-0039-0006 | PC-PA-0039-0007 | PC-PA-0039-9000
Grote, Bret D. (Pennsylvania)
PC-PA-0039-0007 | PC-PA-0039-9000
Gupta, Vanita (District of Columbia)
PC-PA-0039-0002
Hickton, David J. (Pennsylvania)
PC-PA-0039-0002
Kovalik, Daniel (Pennsylvania)
PC-PA-0039-0003 | PC-PA-0039-0006 | PC-PA-0039-9000
McDaniel, Dustin (Pennsylvania)
PC-PA-0039-0003 | PC-PA-0039-0006 | PC-PA-0039-0007 | PC-PA-0039-9000
Defendant's Lawyers Bradley, Scott A. (Pennsylvania)
PC-PA-0039-0007 | PC-PA-0039-9000
Friedline, Mary Lynch (Pennsylvania)
PC-PA-0039-0007 | PC-PA-0039-9000
Warshafsky, Yana L. (Pennsylvania)
PC-PA-0039-0007 | PC-PA-0039-9000
Other Lawyers None on record

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