Montanez v. Price, et al.
3rd Cir. No. 23-2669
Rights Behind Bars represents Jose Montanez, an incarcerated man who suffered sudden paralysis while confined at SCI-Huntingdon, a Pennsylvania state prison. In August 2021, Mr. Montanez collapsed in his cell and lost all sensation from the chest down. Rather than sending him to a hospital, prison staff laughed off his request for emergency care, left him to drag his paralyzed body across his cell floor, and abandoned him for three days before he received an MRI revealing spinal cord stenosis and edema requiring surgery. After surgery, he was returned to prison custody just two weeks later, where staff denied him basic accommodations including a cane, adequate pain medication, and a double mattress, and a prison administrator falsified x-ray results to delay treatment for a herniated disc he suffered in a fall.
Mr. Montanez filed his complaint pro se, but the District Court dismissed it with prejudice, in part because the Middle District of Pennsylvania at the time required incarcerated plaintiffs to state their claims in twelve lines plus three pages—a constraint the court has since eliminated. Rights Behind Bars appealed. In a published opinion, the Third Circuit reversed, reinstating Mr. Montanez's Eighth Amendment and disability discrimination claims and remanding with instructions to allow him to amend his complaint. The Court also held that states cannot evade their obligations under the ADA and Rehabilitation Act by contracting out prison services to private companies.
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