Young v. Martin — prisoner civil rights — reversal — Krause

The Third Circuit today reversed a district court ruling granting summary judgment against a prisoner alleging that his Eighth Amendment rights were violated. The opinion’s introduction gives this cogent summary:

Leonard G. Young, Jr., a Pennsylvania prisoner with a long history of mental illness, filed suit alleging that Appellees-Defendants1 violated his Eighth Amendment rights by securing him in a four-point restraint chair, naked, for fourteen hours, although he did not pose a threat to himself or others. Because we agree with Young that the District Court erred as a matter of law in granting summary judgment against him, we will vacate the judgment and remand for further proceedings.

The opinion also contains a significant discussion of a recent DOJ report on Pennsylvania’s misuse of solitary confinement on prisoners with serious mental illness or intellectual disability.

Joining Krause were McKee and Greenaway. Arguing counsel were Robert Ridge for the prisoner and Kemal Mericli for the AG.