Opinion
CIVIL 1:19-CV-1951
03-21-2022
RALPH MCCLAIN, Plaintiff, v. PENNSYLVANIA DEPARTMENT OF CORRECTIONS, et al. Defendants.
Rambo, Judge
REPORT AND RECOMMENDATION
Martin C. Carlson United States Magistrate Judge
I. Statement of Facts and of the Case
This pro se prisoner lawsuit comes before us for consideration of the plaintiff's motion for preliminary injunction which alleges that personnel at SCI Camp Hill are keeping McClain in an isolated confinement, administrative custody status in violation of his constitutional rights. (Docs. 99 and 100). McClain seeks preliminary injunctive relief in the form of an order directing the defendants to “release the plaintiff to general population from administrative custody in the segregated housing unit at SCI Camp Hill.” (Doc. 99-1 at 1-2). Thus, the motion for preliminary injunction is directed at officials at SCI Camp Hill and seeks to impose a preliminary injunction against those officials.
The defendants have now filed a response to this motion which reports that McClain was transferred to SCI Phoenix on March 16, 2022. (Doc. 102). Accordingly, McClain is no longer housed at SCI Camp Hill. In light of this transfer, the defendants suggest that McClain's request for a preliminary injunction against officials at SCI Camp Hill is now moot.
We agree and recommend that this motion for preliminary injunction be dismissed as moot.
II. Discussion
We find that the plaintiff's transfer from SCI Camp Hill renders moot his current motion for injunctive relief from the defendants, corrections officials at this facility who formerly oversaw the conditions of the plaintiff's imprisonment at that particular facility.
The mootness doctrine recognizes a fundamental truth in litigation: “[i]f developments occur during the course of adjudication that eliminate a plaintiff's personal stake in the outcome of a suit or prevent a court from being able to grant the requested relief, the case must be dismissed as moot.” Blanciak v. Allegheny Ludlum Corp., 77 F.3d 690, 698-99 (3d Cir. 1996). In this case, McClain sought an injunction directing staff at SCI Camp Hill to place him in general population at that institution, yet it is entirely undisputed that McClain is no longer in the defendants' custody and, therefore, no longer receives these services from the prison defendants named in this case.
This simple fact raises a threshold, and insurmountable, obstacle to this motion for injunctive relief relating to conditions at a prison where McClain is no longer incarcerated. Upon consideration, we conclude that the plaintiff's transfer from the prison renders his motion for injunctive relief moot, and that motion should be denied. In this setting, the United States Court of Appeals for the Third Circuit has observed that, when addressing inmate requests for injunctive relief:
As a preliminary matter, we must determine whether the inmates' claims are moot because “a federal court has neither the power to render advisory opinions nor to decide questions that cannot affect the rights of litigants in the case before them.” Preiser v. Newkirk, 422 U.S. 395, 401 (1975) (quotations omitted); see also Abdul-Akbar v. Watson, 4 F.3d 195, 206 (3d Cir.1993). An inmate's transfer from the facility complained of generally moots the equitable and declaratory claims. Abdul-Akbar, 4 F.3d at 197 (former inmate's claim that the prison library's legal resources were constitutionally inadequate was moot because plaintiff was released five months before trial).Sutton v. Rasheed, 323 F.3d 236, 248 (3d Cir. 2003). See Griffin v. Beard, No. 094404, 2010 WL 4642961 (3d Cir. Nov. 17, 2010) (transfer from SCI Huntingdon renders inmate injunctive relief claim moot). Indeed, as this court has previously observed, in a case such as this, where an inmate seeks injunctive relief against his jailers but is no longer housed at the prison where these injunctive claims arose: “[the prisoner-plaintiff's] transfer to another institution moots any claims for injunctive or declaratory relief.” Fortes v. Harding, 19 F.Supp.2d 323, 326 (M.D. Pa. 1998), citing Abdul-Akbar v. Watson, 4 F.3d 195, 206-07 (3d Cir. 1993); Weaver v. Wilcox, 650 F.2d 22, 27 (3d Cir. 1981).
These principles control here and compel denial of this motion for injunctive relief as moot since the prisoner-plaintiff is no longer housed at SCI Camp Hill.
III. Recommendation
Accordingly, for the foregoing reasons, IT IS RECOMMENDED THAT the plaintiff's motion for preliminary injunction, (Doc. 99), be DISMISSED as moot.
The parties are further placed on notice that pursuant to Local Rule 72.3:
Any party may object to a magistrate judge's proposed findings, recommendations or report addressing a motion or matter described in 28 U.S.C. § 636 (b)(1)(B) or making a recommendation for the disposition of a prisoner case or a habeas corpus petition within fourteen (14) days after being served with a copy thereof. Such party shall file with the clerk of court, and serve on the magistrate judge and all parties, written objections which shall specifically identify the portions of the proposed findings, recommendations or report to which objection is made and the basis for such objections. The briefing requirements set forth in Local Rule 72.2 shall apply. A judge shall make a de novo determination of those portions of the report or specified proposed findings or recommendations to which objection is made and may accept, reject, or modify, in whole or in part, the findings or recommendations made by the magistrate judge. The judge, however, need conduct a new hearing only in his or her discretion or where required by law, and may consider the record developed before the magistrate judge, making his or her own determination on the basis of that record. The judge may also receive further evidence, recall witnesses or recommit the matter to the magistrate judge with instructions.