Case: Mayberry v. Maroney

On July 29, 1966, an inmate incarcerated at the State Correctional Institution in Pittsburgh, Pennsylvania brought a pro se lawsuit under 42 U.S.C. § 1983, against the prison's superintendent in the United States District Court for the Western District of Pennsylvania. The plaintiff sought injunctive and monetary relief, alleging that physical abuse and defamation violated his rights under the Eighth and Fourteenth Amendments.

On July 29, 1966, the United States District Court for the Western District of Pennsylvania (Judge Wallace S. Gourley) dismissed the lawsuit, holding that federal courts lacked jurisdiction over the dispute because it involved a state question. On February 20, 1967, the United States Supreme Court refused the plaintiff's petition for writ of certiorari. Mayberry v. Maroney, 386 U.S. 931 (1967). On April 29, 1968, the United States Court of Appeals for the Third Circuit (Per curium) reversed the District Court's dismissal, finding the legal questions presented in the claim were sufficient to merit the court's attention. Mayberry v. Maroney, 394 F.2d 181 (3d Cir. 1968).

On December 6, 1971, the District Court (Judge Hubert Irving Teitelbaum) held that the plaintiff's claim of systematic physical abuse could proceed because, if true, the plaintiff's allegations would amount to a deprivation of constitutional rights under the color of law. Mayberry v. Maroney, 337 F. Supp. 601 (W.D. Pa. 1971). The court, however, dismissed the plaintiff's defamation claims because the plaintiff should have claimed deprivation of the right to a fair trial. The court reasoned that raising such claims is only proper in a criminal case. In 1972, the court certified the lawsuit as a class action.

On January 18, 1973, the court approved a consent decree, in which the defendants agreed to stop confining inmates in the Correctional Institutions basement. The State resumed basement housing in December 1973, but waited until October 17, 1974, to ask the court to vacate the consent decree. On January 15, 1975, the District Court granted the motion without hearing because the named plaintiff had been transferred to another prison. On appeal, the United States Court of Appeals for the Third Circuit (Judge Howard Thomas Markey) remanded, finding that the trial court erred by ruling without an evidentiary hearing. Mayberry v. Maroney, 529 F.2d 332 (3d Cir. 1976). The appellate court reasoned that the plaintiff retained standing as an inmate of the penal system and could take part in the action. On April 24, 1976, the District Court (Judge Teitelbaum) found that the basement detention facility did not violate the Constitution and vacated the consent judgment. Mayberry v. Maroney, 418 F. Supp. 669 (W.D. Pa. 1976).

On July 7, 1977, the Court of Appeals (Judge Caleb Rodney Layton, III) held that the district judge's refusal to recuse himself for partiality was proper but that the consent decree was improperly vacated because the circumstances had not changed. Mayberry v. Maroney, 558 F.2d 1159 (3rd Cir. 1977).

We have neither the docket nor the pleadings in this case.