The opinion of the court was delivered by: IRENAS
Presently before the Court is the summary judgment motion of those defendants who are officials of Camden County, employees of the Camden County Correctional Facility ("CCCF"), or employees of the provider of medical care at CCCF (collectively, "the County defendants"). For the reasons set forth below, the Court will deny the County defendants summary judgment on plaintiffs' conditions of confinement claims and medical care claims, and grant them summary judgment on plaintiffs' legal access claims and free exercise claims.
These are forty-three consolidated actions commenced variously in 1992 and 1993 on behalf of former and present inmates of CCCF. The plaintiffs include pretrial detainees, inmates serving county-jail sentences, and state-sentenced inmates held at CCCF despite eligibility for transfer to a New Jersey state prison.
The present cases present many issues related to a class action filed in 1982 concerning conditions at CCCF and its predecessor, the Camden County Jail. See Camden County Jail Inmates v. Parker, 123 F.R.D. 490. Inmates v. Parker remained unresolved when the present individual actions were filed, and this Court therefore stayed the present actions pending the outcome of Parker. See Ingalls v. Florio, No. 92-2113 (D.N.J. Mar. 13, 1994) (order staying proceedings). Events in the Parker case have extended over a decade, with both County defendants and those defendants who are state officials entering into several consent decrees designed to alleviate overcrowding at the Camden County Jail and, subsequently, at CCCF, by removing state-sentenced inmates to other institutions. However, these various plans remained unfulfilled until a final consent decree in Parker was fashioned in late 1994.
Following the apparent settlement of Parker, this Court vacated the stay governing the present individual cases. See Ingalls, No. 92-2113 (D.N.J. May 12, 1995) (order vacating stay). The inmate plaintiffs herein had sought to maintain their claims as a class action, but this Court denied them class certification. See Ingalls, No. 92-2113 (D.N.J. Sept. 23, 1993) (order denying class certification). Nonetheless, the Court consolidated these actions for purposes of discovery and motion practice. See Ingalls, No. 92-2113 (D.N.J. Mar.15, 1994, Mar. 23, 1994, Apr. 21, 1994, Apr. 28, 1994, and May 6, 1994) (orders consolidating actions for limited purposes).
A. Summary Judgment Standard
Under Federal Rule of Civil Procedure 56(c), "summary judgment is proper 'if the pleadings, depositions, answers to interrogatories, and admissions on file, together with the affidavits, if any, show that there is no genuine issue as to any material fact and that the moving party is entitled to a judgment as a matter of law.'" Celotex Corp. v. Catrett, 477 U.S. 317, 322, 91 L. Ed. 2d 265, 106 S. Ct. 2548 (1986). A non-moving party may not rest upon mere allegations, general denials, or vague statements in opposition to a summary judgment motion. If the non-moving party's evidence is merely colorable, or is not significantly probative, summary judgment may be granted. See Bixler v. Central Pa. Teamsters Health & Welfare Fund, 12 F.3d 1292 (3d Cir. 1993); Trap Rock Indus. Inc. v. Local 825, Int'l Union of Operating Eng'rs, 982 F.2d 884, 890-91 (3d Cir. 1992).
It is not the role of the judge at the summary judgment stage to weigh the evidence or to evaluate its credibility, but to determine "whether there is a genuine issue for trial." Anderson v. Liberty Lobby, Inc., 477 U.S. 242, 249, 91 L. Ed. 2d 202, 106 S. Ct. 2505 (1986). The Court must draw all inferences in the light most favorable to the non-moving party, and where the non-moving party's evidence contradicts the movant's, the Court must accept the non-movant's version as true. See Pastore v. Bell Tel. Co., 24 F.3d 508, 512 (3d Cir. 1994).
The substantive law governing the dispute will determine which facts are material, and only disputes over those facts "that might affect the outcome of the suit under the governing law will properly preclude the entry of summary judgment." Anderson, 477 U.S. at 248. A genuine issue of material fact for trial does not exist "unless the party opposing the motion can adduce evidence which, when considered in light of that party's burden of proof at trial, could be the basis for a jury finding in that party's favor." J.E. Mamiye & Sons, Inc. v. Fidelity Bank, 813 F.2d 610, 618 (3d Cir. 1987) (Becker, J., concurring).
B. Respondeat Superior Liability
The County defendants, who are all supervisory personnel or political officials, generally assert that they cannot be held liable on plaintiffs' claims because they were not "aware of the needs" of particular plaintiffs, did not have "personal knowledge" of particular conditions of confinement, or did not have "personal contact" with plaintiffs. See, e.g., County Defendants' Reply Brief re Archer at 1-3. The plaintiffs, however, allege that the County defendants were well aware of overall conditions at CCCF because of these defendants' involvement in the Inmates v. Parker class action, and because the longstanding difficulties with overcrowding and substandard conditions at CCCF were a matter of common knowledge. See, e.g., Archer Brief at 2-6.
Supervisory personnel or administrators can not be liable for damages under § 1983 on a theory of respondeat superior; rather, they must have played some personal role in causing a plaintiff's alleged harms. See Monell v. Department of Social Services, 436 U.S. 658, 56 L. Ed. 2d 611, 98 S. Ct. 2018 (1978). A civil rights plaintiff must establish an "affirmative link" between the claimed deprivation and the official sued. See Rizzo v. Goode, 423 U.S. 362, 371, 46 L. Ed. 2d 561, 96 S. Ct. 598 (1976); cf. Board of County Comm'rs v. Brown, 137 L. Ed. 2d 626, 117 S. Ct. 1382 (1997) (discussing supervisory liability in § 1983 actions in context of excessive-force claims against police).
Here, the allegations against the County defendants set forth theories of personal responsibility for conditions at CCCF that are sufficient to overcome these defendants' request for summary judgment based on the issue of respondeat superior liability. Plaintiffs clearly maintain that either (1) the County defendants had direct knowledge of the various allegedly unconstitutional conditions at CCCF that resulted in plaintiffs' harms; or (2) the County defendants persisted in promoting the policies that inevitably resulted in the unconstitutional conditions. Those theories, and the history of the long-running CCCF dispute which plaintiffs cite as factual support, might permit a jury to impose liability upon the County defendants under the doctrines of Monell and Rizzo.
C. General Conditions Claims
Plaintiffs allege that their most basic human needs for sanitation, recreation, uncontaminated food, minimally sufficient housing space, and personal safety were not met during their periods of incarceration at CCCF. See, e.g., Archer Brief at 1-2. The County defendants respond that plaintiffs cannot demonstrate the necessary elements of these claims. See, e.g., County Defendants' Brief re Archer at 13-15. Further, as to three particular plaintiffs--Cream, Frazier, and Torres--the County defendants assert that their claims are barred by the applicable statute of limitations. In turn, the Court will discuss (1) the sufficiency of plaintiffs' claims concerning basic human needs (other than personal ...