Scott v. Quigley
Opinion
OPINION
Plaintiff in this action was convicted of robbery in state court on April 17, 2000, and began to serve his sentence. The court granted bail, which plaintiff posted on February 13, 2002. At that time, he was imprisoned in the State Correctional Institution at Somerset (“SCI-Somerset”). He was not released, however, because of detainers lodged against him.
On Thursday, February 28, 2002, the plaintiffs detainers were paid and the court ordered him released on bail. That same day, the Perry County Sheriffs Office sent a certified copy of the order granting the plaintiffs release to officials at SCI-Somerset via United States Postal Service. SCI-Somerset received the order four days later on Monday, March 4. Upon receiving the documents, officials at SCI-Somerset completed verification procedures and approved the plaintiffs release that day.
At that time, Pennsylvania Department of Corrections policies required satisfaction of all outstanding detainers before an inmate could be released. Moreover, an inmate was not to be released on bail until prison officials received an original, certified court order allowing bail, an order setting bail, and a signed receipt that bail was paid. Defendant, Superintendent Sobina, stated that these policies were “necessary for security reasons and [were] required in order to guard against falsification of records and to ensure that the inmate’s release is proper and in accordance with the Court’s instructions.”
Plaintiff alleges he was unlawfully detained during the four days that elapsed between the state court order and his actu *455 al release. He asserted numerous federal and state constitutional claims against various state officials. The District Court dismissed all of the plaintiffs claims except his Eighth and Fourteenth Amendment claims against corrections officials Sobina and Beard. Summary judgment was later entered in their favor. Plaintiff has appealed the grant of summary judgment.
The District Court dismissed the plaintiffs Eighth Amendment claim because he did not show that defendants acted with deliberate indifference. See Moore v. Tartler, 986 F.2d 682, 686 (3d Cir. 1993). The evidence supports the District Court’s conclusion that prison officials responded promptly to the plaintiffs request for information and acted quickly to release him once they received the necessary paperwork. Moreover, plaintiff has not shown that he was denied due process. The regulatory procedures adopted by the Department of Corrections are reasonable and constitutional. See Mathews v. Eldridge, 424 U.S. 319, 335, 96 S.Ct. 893, 47 L.Ed.2d 18 (1976) (applying three-part analysis to determine constitutionality of administrative procedures). The District Court, therefore, properly granted summary judgment for defendants.
Accordingly, we will affirm the Order of the District Court.
Reference
- Full Case Name
- Ronald K. SCOTT, Appellant v. Keith B. QUIGLEY, Honorable Judge; Joseph Rehkamp, Honorable Judge; R. Scott Cramer, District Attorney; Chad Chenot, District Attorney; S.C. Walz, III, Public Defender; Brenda Albright, Clerk of Courts; Elizabeth Frownfetter, District Justice; James Moyer, Jr., District Justice; Jeffrey A. Beard, Commissioner, PA DOC; Ray J. Sobina, Superintendent, SCI Somerset; Perry County, PA; PA Dept of Corrections
- Status
- Unpublished