A federal judge in Philadelphia has dismissed a lawsuit against the Berks County, Pa. prison system that had been filed by a former inmate who claimed that his time in jail was marked by poor treatment and shoddy living conditions.
U.S. District Judge Mary A. McLaughlin granted the prison system’s motion to dismiss March 9 in a case in which former inmate James Walters had sued over incidents relating to his 2010-2011 imprisonment stint.
In his complaint, which was filed in October 2011, Walters claimed that the physical conditions of his cell were unsanitary to the point of violating his constitutional rights.
Walters, who has since been released from custody, alleged that he was made to eat and sleep next to a toilet, and that there was the presence of mice and insects in his prison cell.
He also claimed that he had trouble sleeping at night because the overhead light in his cell was kept on at all times, and that he suffered an infection the size of a silver dollar on his left leg that was not properly cared for, and from which Walters developed a scar and muscle mass loss.
Two months after Walters filed suit, the defendant filed a motion to dismiss, asserting that the plaintiff failed to state a claim of municipal liability.
McLaughlin sided with the defendants.
“The Court agrees, finding that the facts alleged by the plaintiff do not give rise to a constitutional violation and are insufficient to impose municipal liability on [the prison],” the judge wrote in her ruling, which was filed at the U.S. District Court for the Eastern District of Pennsylvania.
Shooting down the plaintiff’s claim that his Eighth Amendment rights were violated, McLaughlin wrote in her ruling that Walters did not establish that the conditions of his cell deprived him of life’s necessities.
“The conditions of the plaintiff’s confinement as stated, while harsh, do not meet the high standard of an ‘extreme deprivation’ required to state a claim for constitutional violations arising out of conditions of confinement,” the ruling states.
McLaughlin also wrote that Walters’ claims regarding his infection do not state a claim under Section 1983 because he acknowledges that he did, in fact, receive medical treatment, and his allegations are ‘conceded to be ones of neglect rather than the ‘deliberate indifference’ required by prison officials for a cognizable constitutional violation.”
The judge also noted that during oral testimony, the defendant made clear that medical treatment at the prison is performed by a third-party contractor rather than prison officials.
McLaughlin also wrote that the municipal liability claims against the prison system cannot move forward because Walters, who is acting pro se, failed to show that his rights were violated pursuant to an official policy or practice of the Berks County prison system.
The judge’s ruling left open the opportunity for Walters to file an amended complaint on or before April 9 that addresses the shortcomings identified in the judge’s memorandum.