Williams v. Secretary Pa. DOC, U.S. App. LEXIS 2414, (U.S. Ct. of App., 3d Cir., September 20, 2024)(McKee, J.)
McKEE, Circuit Judge.
Roy Lee Williams, a death-row prisoner with a history of mental illness, was held in solitary confinement on the Capital Case Unit (CCU) of a Pennsylvania state correctional institution for twenty-six years. Williams filed this action alleging that, given his known history of serious mental illness, being continuously held in solitary confinement for twenty-six years without penological justification violated the Eighth Amendment’s cruel and unusual punishment clause and the Americans with Disabilities Act (ADA). The District Court granted summary judgment for Defendants. It held that Secretary John E. Wetzel, the former Secretary of the Pennsylvania Department of Corrections (DOC), was entitled to qualified immunity on the Eighth Amendment claim and that Williams could not show that the DOC was deliberately indifferent under the ADA.1 Williams now appeals the District Court’s grant of Defendants’ motion for summary judgment on both claims.
Prior to the District Court’s summary judgment decision, on April 1, 2021, the District Court sua sponte dismissed Williams’ Fourteenth Amendment claim, pursuant to 28 U.S.C. § 1915(e)(2)(b)(ii), for failure to state a claim. Williams also appeals that decision.
Our review of the District Court’s decision requires us to draw all reasonable inferences in Williams’ favor, including that the Secretary had knowledge of Williams’ preexisting serious mental illness. We must then determine if the Secretary should have known that holding this death-row prisoner with preexisting serious mental illness in solitary confinement from 1993 to 2019 without penological justification violated the Eighth Amendment.
We conclude that the Secretary had “fair and clear warning” that his conduct was unconstitutional and should have known that keeping Williams in solitary confinement would constitute cruel and unusual punishment. Therefore, the doctrine of qualified immunity does not shield the Secretary from Williams’ Eighth Amendment claim. Our prior precedents and the record before us leave no room for doubt that it has long been clearly established that someone with a known preexisting serious mental illness has a constitutional right not to be held—without penological justification—in prolonged solitary confinement.
The District Court correctly determined that there was a material factual dispute as to whether the DOC knew that Williams had a serious mental illness. However, the court erroneously concluded that a trier of fact could not find that the DOC was deliberately indifferent to the risk of harm it caused by placing and keeping Williams in solitary confinement despite his preexisting serious mental illness.
Accordingly, we will vacate the District Court’s grant of summary judgment on both claims and remand for further proceedings. We will affirm the District Court’s dismissal of Williams’ Fourteenth Amendment claim.
Nonetheless, at the time of Williams’ confinement, the due process rights of an active death-row prisoner had not been clearly established. The Court in Williams I held that individuals on death row who had been granted resentencing hearings had a liberty interest that prohibited the state from housing them in solitary confinement on death row without “regular and meaningful review of their continued placement. “However, we did not reach a conclusion as to whether the due process clause of the Fourteenth Amendment limited the State’s ability to subject prisoners with active death row sentences to prolonged solitary confinement. Similarly, in Porter we did not reach a determination as to whether prisoners with active death row sentences had a procedural due process claim. Given that we have not determined whether an active death-row prisoner has a procedural due process interest in avoiding continued solitary confinement, the DOC is entitled to qualified immunity on this claim.
For the above reasons, we will affirm the District Court’s order dismissing Williams’ Fourteenth Amendment claim, and we will vacate the District Court’s order granting summary judgment for the Secretary on Williams’ Eighth Amendment and ADA claims and remand for further proceedings consistent with this opinion.
