Opinion
1:22-cv-111
01-18-2023
WILLIAM HAROLD WRIGHT, JR., Plaintiff v. WARDEN HUTCHINSON, et al, Defendants
ORDER ON PLAINTIFF'S MOTION FOR PRELIMINARY INJUNCTION
[ECF NO. 14]
RICHARD A. LANZILLO Chief United States Magistrate Judge
I. Recommendation
It is respectfully recommended that Plaintiff's Motion for Preliminary Injunction [ECF No. 14] be denied as moot.
II. Report
A. Background
Plaintiff William Harold Wright, Jr. initiated this action on April 1, 2022, by lodging his Complaint. ECF No. 1. The Court ultimately granted Wright's request for leave to proceed in forma pauperis and ordered the U.S. Marshal to serve his Complaint. ECF No. 8.
In his pleading, Wright, an inmate formerly incarcerated at FCI-McKean, claims that the Warden and several staff members at FCI-McKean violated his constitutional rights by placing him on mattress restriction, denying him extra toilet paper and cleaning supplies, blocking medical care for a toothache and shoulder pain, and engaging in unlawful retaliation. ECF No. 9. In the present motion for injunctive relief, Wright contends that he has been forced to sleep on a steel bed without a mattress, causing him to experience stress, high blood pressure, and back and shoulder pain. ECF No. 14 ¶ 2. Defendants, in response, maintain that Wright's request for injunctive relief is both meritless and moot. ECF No. 20 at n. 2. For the following reasons, Wright's motion should be denied.
B. Standard
A party seeking preliminary injunctive relief has the burden of demonstrating: (1) a reasonable probability of success on the merits; (2) irreparable harm if the injunction is denied; (3) that the issuance of an injunction will not result in greater harm to the non-moving party; and (4) that the public interest would best be served by granting the injunction. Council of Alternative Political Parties v. Hooks, 121 F.3d 876, 879 (3d Cir. 1997); Opticians Ass'n of America v. Independent Opticians of America, 920 F.2d 187, 191-92 (3d Cir. 1990). Because the purpose of preliminary injunctive relief is to prevent irreparable injury pending the resolution of the underlying claims on their merits, “the injury claimed in the motion for preliminary injunctive relief must relate to the conduct alleged and permanent relief sought in the plaintiff s complaint.” James v. Varano, 2017 WL 895569, at *3 (M.D. Pa. Mar. 7, 2017). Moreover, where the requested preliminary injunction “is directed not merely at preserving the status quo but;.. at providing mandatory relief, the burden on the moving party is particularly heavy.” Punned v. Carter, 621 F.2d 578, 582 (3d Cir. 1980). Thus, a request for any form of mandatory prospective relief in the prison context “must always be viewed with great caution because judicial restraint is specially called for in dealing with the complex and intractable problems of prison administration.” Goff v. Harper, 60 F.3d 518, 520 (8th Cir. 1995).
C. Analysis
As noted above, Wright seeks injunctive relief in response to the prison's decision to place him on mattress restriction. Defendants, however, have submitted uncontradicted evidence indicating that Wright's disciplinary mattress restriction was removed on July 8, 2022. ECF No. 21-7. Defendants also explain that the mattress restriction was only imposed during the daytime, and that Wright was always provided a mattress to sleep on at night (notwithstanding his own occasional refusal to accept his mattress). Id. ¶¶ 8-10. Finally, the Court notes that Wright has recently been transferred from FCI-McKean and is now incarcerated at FCI-Otisville in Otisville, New York. ECF No. 34.
It is “axiomatic that the federal courts may not decide an issue unless it presents a live case or controversy.” Abdul-Akbar v. Watson, 4 F.3d 195, 206 (3d Cir. 1993). 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 [claim] must be dismissed as moot.” Blanciak v. Allegheny Ludlum Corp., 77 F.3d 690, 698-99 (3d Cir. 1996). Apropos to the instant motion, courts have widely recognized that a request for injunctive relief should generally be denied as moot where the plaintiff is no longer subject to the allegedly unconstitutional condition. Id. See also Weaver v. Wilcox, 650 F.2d 22, 27 (3d Cir. 1981) (“[A] prisoner lacks standing to seek injunctive relief if he is no longer subject to the alleged conditions he attempts to challenge.”). Similarly, an inmate's transfer or release from a correctional institution moots any claims for injunctive or declaratory relief against the offending institution. See, e.g., Rosa-Diaz v. Harry, 2017 WL 6806795, at *5 (M.D. Pa. Dec. 6, 2017) (inmate's transfer from the offending prison facility rendered his request for injunctive relief moot); Sutton v. Rasheed, 323 F.3d 248 (3d Cir. 2003) (“An inmate's transfer from the facility complained of generally moots [his] equitable and declaratory claims.”).
Such is the case here. Because Wright is no longer subject to the allegedly unconstitutional mattress restriction and has been transferred to another facility, it is recommended that his motion for preliminary injunction be denied as moot.
Even if Wright's motion presented a live controversy, it would still fail as a matter of law. It is well-settled that restrictions on bedding items, such as sheets, pillows, blankets, and mattresses, do not ordinarily “rise to the level of a deprivation of basic human needs, such as food, clothing, and shelter.” Brooks v. Bledsoe, 682 Fed.Appx. 164, 170 (3d Cir. 2017). Thus, courts have widely rejected constitutional claims premised on the temporary denial of such items. See, e.g., Freeman v. Miller, 615 Fed.Appx. 72, 77-78 (3d Cir. 2015) (finding no violation where suicidal inmate was placed in a “hard cell” for seven days without a desk, seat, shower, mattress, soap, recreation, mail, or toilet paper); Adderly v. Ferrier, 419 Fed.Appx. 135, 139-40 (3d Cir. 2011) (deprivation of clothing, toiletries, legal mail, a pillow, and a mattress for approximately fourteen days “may have been harsh” but did not “constitute a denial of the minimal civilized measures of life's necessities.”) (internal quotations omitted); Alfred v. Bryant, 378 Fed.Appx. 977, 980 (11th Cir. 2010) (“Objectively speaking, sleeping on a steel bed without a mattress for eighteen days, though uncomfortable, is not so extreme as to violate contemporary standards of decency.”); Knight v. Wap insky, 2013 WL 786339, at *5-6 (M.D. Pa. Mar. 1, 2013) (no constitutional violation from being forced to sleep directly on a concrete floor for approximately six weeks in the absence of allegations that the conditions were unsafe or unsanitary). This is particularly true where, as here, uncontradicted evidence indicates that Wright was only denied a mattress during the daytime hours. ECF No. 21-7.
III. Conclusion
For each of the foregoing reasons, Wright's request for a preliminary injunction [ECF No. 14] should be denied as moot.
IV. Notice
In accordance with 28 U.S.C. § 636(b)(1) and Fed.R.Civ.P. 72, the parties may seek review by the district court by filing Objections to the Report and Recommendation within fourteen (14) days of the filing of this Report and Recommendation. Any party opposing the objections shall have fourteen (14) days from the date of service of Objections to respond thereto. See Fed.R.Civ.P. 72(b)(2). Failure to file timely objections may constitute a waiver of appellate rights. See Brightwell v. Lehman, 631 F.3d 187,194 n.7 (3d Cir. 2011); Nara v. Frank, 488 F.3d 187 (3d Cir. 2007).