SINGLETARY V. PENNSYLVANIA DEPARTMENT OF CORRECTIONS 266 F.3d 186 (3rd Cir. 2001) CASE BRIEF

SINGLETARY V. PENNSYLVANIA DEPARTMENT OF CORRECTIONS

266 F.3d 186 (3rd Cir. 2001)

NATURE OF THE CASE: This was an appeal from a grant of summary judgment for Pennsylvania Department of Corrections (D) in a lawsuit brought by Dorothy Singletary (P), the mother of Edward Singletary, a prisoner who committed suicide while incarcerated. P appeals the grant of summary judgment in favor of defendant Mazurkiewicz.

FACTS: Edward was serving a 6-12 year sentence for his conviction of rape. He was transferred to the maximum security restricted housing unit as a result of 'threatening an employee or family with bodily harm.' Over the next ten months, he became increasingly agitated, acting hostilely to the staff and accusing them of tampering with his food and mail. He was given chances to leave the MSRHU and re-enter the general population but he refused each time. Singletary was seen weekly by a counselor, monthly by a three-person Program Review Committee, and by medical and psychological staff as needed. A Dr. Abdollah Nabavi, prescribed an anti-depressant to help with sleeplessness and anxiety. Nabavi also offered Trilafon, an anti-psychotic drug, because he thought that Singletary was [psychotic] and if not he was very close to being psychotic.' Because of further threats, Singletary was transferred to a cell in the 'Deputy Warden' (DW) building with the approval of the prison Superintendent, defendant Joseph Mazurkiewicz. Singletary was seen the next day by Kevin Burke, a psychiatrist consultant for SCI-Rockview, and by Robert Regan, a psychological services staff member and the person whom P seeks to add as a defendant. Regan did not have any administrative or supervisory duties at the prison. Regan had met with and evaluated Singletary on a weekly basis. During the current meeting, Singletary vehemently denied to both of them at that time that he was suicidal. On the basis of these examinations, neither Regan nor Burke saw any reason to take further precautions for Singletary. Just after midnight on October 6, 1996, Singletary committed suicide by hanging himself with a bedsheet. On October 6, 1998, P filed a 1983 deliberate indifference lawsuit alleging cruel and unusual punishment in violation of the Eighth Amendment along with pendent state law claims for wrongful death. The complaint also named 'Unknown Corrections Officers.' Ds moved for judgment on the pleadings pursuant to Federal Rule of Civil Procedure 12(c), and on May 28, 1999, the District Court granted this motion in part by dismissing P's 1983 claims against these defendants on Eleventh Amendment grounds, but denied their motion to dismiss the pendent state claims on sovereign immunity grounds. On June 23, 2000, Ds moved for summary judgment. P moved to amend her complaint to add Regan as a defendant. The District Court denied the motion on the grounds that that claim would be barred by the statute of limitations because it did not meet the conditions for relation back in Federal Rule of Civil Procedure 15(c)(3). The remaining claims were dismissed on Ds' motions. This appeal followed.

ISSUE:

RULE OF LAW:

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LEGAL ANALYSIS:

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