SCRANTON – An inmate who suffered serious injuries when the porcelain toilet he was using in his prison cell collapsed and shattered beneath him, has lost his constitutional rights violations case against corrections officials through summary judgment.
U.S. Magistrate Judge Martin C. Carlson granted a summary judgment motion filed by Superintendent of SCI-Dallas Kevin Ransom, Facility Safety and Management official Paul Mooney and Department of Corrections Operations official Norman Klinikowski, in an action brought by plaintiff Jeffrey Love Dawkins.
“Dawkins’ case arises out of a singular and singularly-unexpected event: On Jan. 15, 2020, the porcelain toilet in Dawkins’ cell shattered underneath him while he was using this facility, and Dawkins was injured when shards of porcelain pierced him. For their part, the defendants concede that there was an unfortunate accident in Dawkins’ cell relating to the collapse of this toilet but have filed a motion for summary judgment, which disputes whether this incident rose to the level of an Eighth Amendment violation,” Carlson said.
In the wake of the incident, Dawkins suffered cuts to his buttocks and left wrist. He required eight stitches to close the wound on his buttocks and an additional six to seven stitches on his wrist injury. Dawkins remained at the prison infirmary for approximately two weeks while he was treated for his injuries.
Dawkins then filed a lawsuit, alleging that he was subjected to cruel and unusual punishment on the part of the defendants, claiming that the defendants “displayed deliberate indifference to the serious risk to his health and safety presented by the sudden collapse of this toilet.”
“With respect to this pending summary judgment motion, it is entirely uncontested that this event was both unprecedented and unexpected. Prior to Jan. 15, 2020, Dawkins had experienced no problems with this toilet. Moreover, prison officials have attested that they had never previously encountered a mishap of this type, the catastrophic failure and collapse of a porcelain toilet resulting in injuries to an inmate. Dawkins has framed his constitutional tort claims in this case in terms of an alleged violation of the Eighth Amendment’s prohibition against cruel and unusual punishment,” Carlson said.
Carlson explained that in order to establish an Eighth Amendment violation, Dawkins must “show that prison officials were deliberately indifferent to a serious risk to his health and safety” – but added that any such claim was immediately defeated by the fact that the events which gave rise to the litigation were completely “unexpected, unforeseen and unprecedented.”
“Given that Eighth Amendment claims are governed by this subjective deliberate indifference standard, Dawkins’ complaint runs afoul of an insurmountable obstacle: This accident, and Dawkins’ injuries, were entirely unexpected, unforeseen and unprecedented. Since mere negligence or inadvertence with not suffice to establish a violation of the Eighth Amendment’s prohibition against cruel and unusual punishment, the fact that no one anticipated this extraordinary event – the sudden, catastrophic implosion of a porcelain toilet while in use – defeats any deliberate indifference claim,” Carlson said.
“Simply put, facts are stubborn things, and the undisputed facts in this case show that neither Dawkins, nor the defendants, had any reason to anticipate that this toilet would violently implode while in use. Since the defendants cannot be deliberately indifferent to unprecedented and unknown mishaps or dangers, the lack of any foreseeability to this accident rebuts any Eighth Amendment claim that the defendants were deliberately indifferent to a known risk to Dawkins’ safety and compels the dismissal of this complaint.”
In addition, Carlson found that the defendants were entitled to qualified immunity from any claims.
“Just as the wholly unanticipated nature of this mishap defeats any claim of deliberate indifference, it follows that the defendants’ conduct in failing to anticipate an unknown hazard presented by the sudden implosion of a toilet could not have transgressed clearly established case law. Accordingly, the defendants are also entitled to qualified immunity and the defendants’ motion for summary judgment will be granted,” Carlson concluded.
U.S. District Court for the Middle District of Pennsylvania case 3:20-cv-01467
From the Pennsylvania Record: Reach Courts Reporter Nicholas Malfitano at nick.malfitano@therecordinc.com