Introduction

In Mark C. Rokita, Jr. v. Scott Klinefelter, et al., the United States Court of Appeals for the Third Circuit (per curiam) affirmed the dismissal with prejudice of a pro se incarcerated person’s civil rights and ADA claims arising from medical treatment and disciplinary events at SCI Houtzdale between August and October 2022. Although designated “not precedential” under I.O.P. 5.7, the opinion provides clear, practical guidance on four recurring areas in prison litigation:

• What a prisoner must plausibly plead to link alleged retaliation to protected First Amendment activity;
• How the Eighth Amendment “deliberate indifference” standard distinguishes medical judgment from unconstitutional denial of care;
• Why Title II ADA damages require “intentional discrimination” under a deliberate indifference standard, and why adherence to safety-based MAT protocols (here, denying Vivitrol after recent Suboxone use) does not meet that bar;
• How harmless-error and post-deprivation remedy doctrines dispose of procedural due process challenges to disciplinary proceedings and property deprivations.

The defendants included a nurse (Tara Johns), a correctional official (Jason Vello), a supervisory official (Scott Klinefelter), and Wellpath Medical, the prison’s healthcare contractor. The District Court screened and dismissed the complaint under 28 U.S.C. § 1915(e)(2)(B)(ii). Rokita was released in July 2024; his injunctive claims were therefore moot. On appeal, the Third Circuit addressed only the issues he briefed and affirmed across the board.

Summary of the Opinion

• First Amendment Retaliation: Dismissal affirmed. The complaint did not plausibly allege that Nurse Johns knew about Rokita’s prior court action; speculation based on a newspaper article was insufficient to plead the causation element. See Mitchell v. Horn.
• Eighth Amendment Medical Care: Dismissal affirmed. The allegations showed at most a disagreement with or dissatisfaction over analgesic strength (Tylenol after hernia surgery) and an unexplained delay in a follow-up call—insufficient to show deliberate indifference by Nurse Johns. Claims against Wellpath and Klinefelter failed for lack of policy/custom and personal involvement, respectively. See Pearson; Rouse; Inmates of Allegheny County Jail; Natale; Iqbal.
• ADA (Title II): Dismissal affirmed. Prospective relief was moot post-release. Damages require intentional discrimination under a deliberate indifference standard. Denial of Vivitrol after recent Suboxone (buprenorphine) use reflected medical judgment grounded in safety (risk of adverse reaction), not intentional disability-based discrimination. See Durham; S.H. ex rel. Durrell; 28 C.F.R. pt. 36, app. C. The court took judicial notice of FDA materials regarding buprenorphine.
• Fourteenth Amendment Due Process: Dismissal affirmed. Any unauthorized property deprivation was redressable via adequate post-deprivation remedies (Hudson; Tillman). Any procedural deficiency in the disciplinary hearing (exclusion of witnesses) was harmless because Rokita admitted Suboxone use; additional testimony about the urine test could not have altered the outcome. See Elkin; Pannell.
• Seventh Amendment: Screening dismissal does not violate the right to a jury trial. See Haase.

Detailed Analysis

A. Precedents Cited and Their Role in the Decision

• Pleading/Screening Standards:
  • Ashcroft v. Iqbal, 556 U.S. 662 (2009): A complaint must state a plausible claim; § 1983 does not permit respondeat superior. The court invoked Iqbal both for plausibility and to reject vicarious liability theories.
  • Henderson v. Carlson, 812 F.2d 874 (3d Cir. 1987); Vogt v. Wetzel, 8 F.4th 182 (3d Cir. 2021): De novo review of screening dismissals and liberal construction of pro se pleadings.
  • Fleisher v. Standard Ins. Co., 679 F.3d 116 (3d Cir. 2012); Murray v. Bledsoe, 650 F.3d 246 (3d Cir. 2011): Accept well-pleaded facts as true; appellate court may affirm on any ground supported by the record.
• First Amendment Retaliation:
  • Mitchell v. Horn, 318 F.3d 523 (3d Cir. 2003): Retaliation requires protected conduct, adverse action, and a causal link; the panel used Mitchell to require plausible allegations that the defendant knew of the protected conduct.
• Eighth Amendment Medical Care:
  • Pearson v. Prison Health Service, 850 F.3d 526 (3d Cir. 2017): Two-part test—serious medical need and deliberate indifference.
  • Rouse v. Plantier, 182 F.3d 192 (3d Cir. 1999): Deliberate indifference where officials intentionally refuse care, delay for non-medical reasons, or prevent access to needed care.
  • Inmates of Allegheny County Jail v. Pierce, 612 F.2d 754 (3d Cir. 1979): Courts will not second-guess medical judgment; treatment adequacy is within professional judgment.
  • Natale v. Camden County Corr. Facility, 318 F.3d 575 (3d Cir. 2003): Private medical contractor liability arises only from policy or custom causing the violation; respondeat superior does not apply.
• ADA Title II:
  • Durham v. Kelly, 82 F.4th 217 (3d Cir. 2023): Title II elements and requirement of “intentional discrimination” for compensatory damages, measured by deliberate indifference (knowledge of likely violation and failure to act).
  • S.H. ex rel. Durrell v. Lower Merion Sch. Dist., 729 F.3d 248 (3d Cir. 2013): Aligns ADA/Rehabilitation Act damages “deliberate indifference” with § 1983 standards.
  • Yeskey v. Commonwealth of Pa. Dep’t of Corr., 118 F.3d 168 (3d Cir. 1997): Inmate claims for injunctive relief under ADA can become moot upon release.
  • 28 C.F.R. pt. 36, app. C (DOJ guidance): Permits clinicians to consider drug use in determining appropriate medical treatment—cited to validate safety-based MAT decisions.
• Due Process:
  • Hudson v. Palmer, 468 U.S. 517 (1984): Unauthorized intentional property deprivations are not due process violations if adequate post-deprivation remedies exist.
  • Tillman v. Lebanon County Corr. Facility, 221 F.3d 410 (3d Cir. 2000): Pennsylvania DOC grievance procedures provide adequate post-deprivation remedies.
  • Elkin v. Fauver, 969 F.2d 48 (3d Cir. 1992): Harmless-error analysis applies to procedural challenges in prison disciplinary hearings.
  • Pannell v. McBride, 306 F.3d 499 (7th Cir. 2002): Prison may deny witnesses whose testimony is irrelevant, repetitive, or unnecessary; used to support harmlessness where the inmate admitted the core misconduct.
• Other:
  • Haase v. Countrywide Home Loans, Inc., 748 F.3d 624 (5th Cir. 2014): A Rule 12 dismissal does not violate the Seventh Amendment; used analogously for § 1915 screening.

B. The Court’s Legal Reasoning

1. First Amendment Retaliation (against Nurse Johns):

   The panel focused on causation. Rokita alleged he previously filed a state-court action seeking Medication Assisted Treatment (MAT) access and that a newspaper article about that suit circulated. He inferred that Nurse Johns retaliated by denying him medication. The court held this insufficient because the complaint did not allege facts showing that Johns knew about the lawsuit (for example, that she read the article or that someone told her). Under Mitchell, without knowledge, there can be no plausible retaliatory motive. Conclusory statements that it was “apparent” she acted because of the suit do not nudge causation over the plausibility line.

2. Eighth Amendment Medical Care:

   The court assumed serious medical need (post-hernia-surgery pain) but found no deliberate indifference. The complaint itself showed that Johns saw Rokita the day after surgery and provided Tylenol; Rokita’s preference for stronger analgesia is a treatment disagreement that courts will not second-guess (Inmates of Allegheny County Jail). As to subsequent delay (three days without being called back and being turned away once for improper dress due to pain), the complaint did not plausibly allege that Johns caused or knew of and disregarded that delay, or that she prevented needed care (Rouse). Nor did Rokita allege further sick-call requests after that date, undermining any inference of ongoing deliberate indifference.

   Claims against Wellpath and Klinefelter failed for independent reasons. Invoking Iqbal and Natale, the court held:

   • Wellpath cannot be held vicariously liable under § 1983; the complaint lacked allegations of a specific Wellpath policy or custom causing the alleged constitutional violation.
   • Klinefelter’s personal involvement was not plausibly pled; § 1983 requires personal participation, direction, or knowledge/acquiescence in the violation.
3. ADA Title II (against public entity; nurse’s conduct at issue):

   With injunctive and declaratory relief mooted by Rokita’s release (Yeskey), only damages remained. Durham and S.H. require “intentional discrimination,” met by deliberate indifference—knowledge of a substantial likelihood of an ADA violation and failure to act.

   Rokita alleged that, as an opioid-addicted individual, he sought Vivitrol (naltrexone) as MAT. A few days before his scheduled dose, he took illicit Suboxone (buprenorphine). His urine screen was positive for buprenorphine; he admitted the use. The nurse canceled treatment, allegedly exclaiming that he was “not getting treatment.” The court took judicial notice that buprenorphine use can contraindicate immediate Vivitrol due to risk of precipitated withdrawal and other adverse reactions (citing FDA labeling) and relied on DOJ guidance allowing clinicians to consider drug use when determining appropriate medical care (28 C.F.R. pt. 36, app. C).

   On those facts, the nurse’s decision reflected medical judgment and safety-based clinical protocol, not intentional disability-based discrimination. Put differently, the denial was because of recent buprenorphine ingestion, not “by reason of” Rokita’s disability (opioid use disorder). And even if the decision were debatable medically, it would not rise to “deliberate indifference” under the ADA damages standard.

4. Procedural Due Process:

   Property deprivation claim: If Officer Vello’s alleged six-month deprivation of educational materials was unauthorized by prison policy, Hudson and Tillman bar a § 1983 due process claim because adequate post-deprivation remedies (DOC grievance procedures) exist.

   Disciplinary hearing claim: Even assuming a procedural defect (exclusion of witnesses), Elkin’s harmless-error standard applied. Rokita was charged with possession or use of a controlled substance and had admitted Suboxone use to medical staff. Proposed witness testimony about the urine screen would not have altered the outcome; thus any error was harmless. The panel also noted that prisons may deny cumulative, irrelevant, or unnecessary witnesses (Pannell).

   The court further rejected a confidentiality theory derived from a policy that, by its own terms, covered “psychological evaluation or treatment,” not general medical disclosures in this context, and thus could not support a due process violation.

5. Seventh Amendment:

   Consistent with Haase, dismissal at the screening stage under § 1915(e)(2) does not infringe the right to a jury trial where the complaint fails to state a legal claim.

C. Impact and Practical Implications

• Retaliation Pleading: Prisoner-plaintiffs must plead facts showing the defendant’s knowledge of the protected activity to plausibly allege causation. Generalized allegations that “staff” knew, or inferences drawn from the existence of a newspaper article, are insufficient unless tied to the specific defendant (e.g., statements, emails, grievances, or other communications).
• Medical Judgment vs. Deliberate Indifference: The opinion reinforces a high bar for Eighth Amendment claims premised on analgesic disputes or single-episode delays without facts showing intentional refusal, non-medical delay, or obstruction. Plaintiffs should document repeated requests, explicit refusals, or non-medical reasons for delay to state a claim.
• Private Medical Contractors and Supervisors: Following Natale and Iqbal, plaintiffs must identify a policy/custom (practices, training gaps, or patterns) causing harm to sue entities like Wellpath, and must allege personal involvement to sue supervisors. Bare status-based naming will be dismissed.
• ADA Damages and MAT Protocols: For Title II damages, plaintiffs need factual allegations that an official knew of a substantial risk of ADA violation and disregarded it. Safety-based deviations—such as withholding Vivitrol in the face of recent buprenorphine ingestion—will generally be treated as medical judgment, not intentional discrimination. This is a significant practical signal for prison systems implementing MAT: adherence to clinical contraindications can defeat ADA damages claims, provided decisions are tied to safety rather than disability-based animus or stereotypes.
• Mootness on Release: Post-release, injunctive and declaratory relief claims connected to prison conditions are commonly moot. Former inmates should focus on damages claims and ensure they meet the intent standards applicable to the statute invoked.
• Disciplinary Due Process: Harmless-error doctrine has real teeth in prison discipline. Where an inmate admits the core misconduct, exclusion of witnesses whose testimony would be cumulative or immaterial will not warrant relief. Property deprivation claims must proceed through (and plead inadequacy of) state post-deprivation remedies to survive under Hudson/Tillman.
• Judicial Notice of Medical Facts: The panel’s use of FDA labeling to take judicial notice of well-known medical facts at the pleading stage highlights that courts may resolve certain medical-compatibility issues without discovery when the facts are authoritative and undisputed.

Complex Concepts Simplified

• Deliberate Indifference (Eighth Amendment): Not every bad outcome or disagreement with treatment is unconstitutional. Deliberate indifference requires knowing about a serious need and intentionally refusing care, delaying care for non-medical reasons, or blocking access to needed care. Simple negligence or a difference in medical opinion is not enough.
• Title II of the ADA—Damages Standard: To recover money damages, a plaintiff must show the public entity (or its responsible official) acted with “intentional discrimination,” which in this context means deliberate indifference—knowing a violation of ADA rights was likely and failing to act. Clinically justified decisions generally do not meet this standard.
• Medical-Assisted Treatment (MAT) and Safety: Vivitrol (naltrexone) can precipitate withdrawal if opioids like buprenorphine (in Suboxone) are still in the system. A clinician’s decision to defer Vivitrol until the body is clear of opioids is a safety-driven judgment, not an anti-disability action.
• Monell-Type Liability for Private Medical Providers: Private contractors like Wellpath are not automatically liable for their employees’ actions. A plaintiff must identify a specific policy or custom that caused the constitutional violation.
• Retaliation Causation: A plaintiff must connect the dots between protected activity and adverse action by showing the defendant knew about the protected activity and acted because of it. Suspicion without facts tying knowledge to the decision-maker is insufficient.
• Harmless Error in Disciplinary Proceedings: Even if a procedural rule was not followed (e.g., a witness was excluded), there is no due process violation unless the error likely affected the outcome. If the inmate’s own admissions establish the offense, additional testimony may be deemed unnecessary.
• Post-Deprivation Remedies: When officials randomly or unauthorizedly deprive property, due process is satisfied if the state provides an adequate procedure to seek redress after the fact (e.g., grievance systems). Federal due process claims generally fail if such remedies exist and were available.
• Mootness After Release: Courts generally will not issue injunctive or declaratory relief about prison conditions once a person is released, because the risk of the same injury recurring to the same person is too speculative.

Conclusion

Although nonprecedential, Rokita v. Klinefelter offers crisp, practical guidance for pleading and proving prison-based First Amendment, Eighth Amendment, and ADA claims:

• Retaliation requires plausible allegations that the specific defendant knew about the protected activity and acted because of it.
• Eighth Amendment medical claims fail where the facts reflect clinical judgment, limited analgesia, or unexplained delays without showing intentional refusal, non-medical delay, or obstruction.
• Title II damages require intentional discrimination—medical safety decisions, like deferring Vivitrol when buprenorphine remains in the system, are not deliberate indifference to ADA rights.
• Due process challenges to disciplinary outcomes are subject to harmless-error review; property claims are typically diverted to state post-deprivation remedies.
• Entity and supervisory liability demands allegations of policy/custom or personal involvement—not job titles.

For correctional health systems, the opinion underscores that adherence to established, safety-based MAT protocols aligns with both Eighth Amendment and ADA obligations. For litigants, the decision is a reminder that plausibility hinges on concrete facts: knowledge, causation, intent, and policy. Dismissal at screening will be affirmed where those elements are missing.

Case Information

Court: United States Court of Appeals for the Third Circuit (per curiam; not precedential)
Panel: Judges Hardiman, Matey, and Chung
Date: November 13, 2025
Docket: No. 24-2197; appeal from W.D. Pa., No. 3:23-cv-00158 (Judge Stephanie L. Haines)
Disposition: Affirmed (dismissal with prejudice under 28 U.S.C. § 1915(e)(2)(B)(ii))
Scope: Issues raised on appeal only (Kost v. Kozakiewicz)