When Christian Lauria, a pro se prisoner-plaintiff, attempted to sue for a violent assault by corrections officers, the court threw out his case on a technicality—one he had never been told existed in the first place. The MacArthur Justice Center is fighting to ensure that pro se prisoners like Mr. Lauria get their day in court when they seek to hold corrections officers accountable for wrongdoing.
While being processed for intake at the Allegheny County Jail in Pennsylvania, Christian Lauria was brutally assaulted by three corrections officers, rendering him unconscious. The officers then placed Mr. Lauria in a restraint chair and left him there for hours, rejecting his requests for medical attention. As a result of this brutality and lack of prompt medical treatment, Mr. Lauria sustained a broken orbital floor, an injury that required surgery and implementation of mesh under his eye.
Following these events, Mr. Lauria submitted an administrative grievance against the officers using the jail’s standard procedure: he placed the grievance in the slot of his cell door, relying on a corrections officer to pick it up and place it in the appropriate grievance box for processing. Although the grievance was taken, Mr. Lauria received no response, and the Deputy Warden subsequently attested that she did not find any records of the grievance in the jail’s database.
Mr. Lauria—acting pro se, or without counsel—then filed a lawsuit against the Allegheny County Jail and the corrections officers who beat him. The district court granted summary judgment against Mr. Lauria for failing to exhaust the jail’s grievance process as required by the Prison Litigation Reform Act, citing the Deputy Warden’s attestation. The court acknowledged Mr. Lauria’s uncontested explanation that he did submit a grievance and relied on corrections officers to file it for him, but concluded that it could not consider this explanation as evidence because Mr. Lauria did not sign it under penalty of perjury—a legal technicality that neither the court nor opposing counsel informed Mr. Lauria, a pro se prisoner without legal training, he was required to satisfy for his explanation to constitute admissible evidence.
The MacArthur Justice Center represents Mr. Lauria on appeal to the U.S. Court of Appeals for the Third Circuit to ensure that pro se prisoners like him not be tossed out of court based on technicalities they can’t be expected to know or understand.