Background
Eric Maple, a pro se inmate then housed at SCI-Houtzdale, began refusing institutional meals on August 17, 2019, in a self-imposed hunger strike. The Department of Corrections (DOC) transferred him to the Restricted Housing Unit (RHU)—a Level 5 security housing unit—to permit continuous medical monitoring, consistent with DOC Policy 13.1.1 governing inmate hunger strikes. While Maple was in the RHU, prison officials confiscated food items he had previously purchased through the prison commissary and restricted his ability to make new commissary food purchases. Throughout the period, however, DOC offered Maple institutional meals multiple times daily and provided daily medical monitoring visits, charging a $5.00 co-pay per visit from his inmate account (totaling $10.00).
In April 2020, Maple filed a petition for review in the Commonwealth Court’s original jurisdiction. He alleged two constitutional violations: (1) that confiscating and restricting his commissary food during a self-imposed hunger strike constituted cruel and unusual punishment in violation of the Eighth Amendment; and (2) that the $10.00 in medical co-pays violated the Fourteenth Amendment’s Due Process Clause because he was not ill or injured. The court dismissed the Fourteenth Amendment claim on demurrer in 2021. The surviving Eighth Amendment claim proceeded through DOC’s answer and new matter. Maple then filed an Application for Summary Relief (ASR) under Pa. R.A.P. 1532(b), asserting his right to relief was clear as a matter of law. DOC opposed, raising a genuine dispute over whether its policies permitted confiscation of already-purchased commissary items.
The Court’s Holding
Judge Wojcik, writing for a unanimous panel, denied Maple’s ASR. Summary relief under Pa. R.A.P. 1532(b) requires that the applicant’s right to relief be “clear” and that no genuine issue of material fact exist, with the evidence viewed in the light most favorable to the non-moving party—here, DOC. The Eighth Amendment’s prohibition on cruel and unusual punishment requires an inmate to satisfy both an objective prong (a “sufficiently serious” deprivation of a minimal civilized life necessity or substantial risk of serious harm) and a subjective prong (prison officials’ “deliberate indifference,” meaning actual knowledge of and disregard for an excessive risk to inmate health or safety). Farmer v. Brennan, 511 U.S. 825 (1994).
The court identified two independent reasons to deny the ASR. First, a genuine issue of material fact precluded summary relief: the parties disputed whether DOC Policy DC-ADM 815—which restricts Level 5 commissary purchasing privileges—also authorized confiscation of food items Maple had already purchased before his RHU transfer. The policy was silent on that question, and DOC’s denial of Maple’s allegation created a fact dispute that precluded a finding that Maple’s right to relief was clear. Second, even setting aside that dispute and assuming arguendo that the confiscation was impermissible, Maple still could not satisfy the Eighth Amendment’s objective or subjective prongs. Objectively, Maple was deprived only of commissary food supplements—not food altogether—because institutional meals were offered multiple times daily throughout the hunger strike. His refusal to eat those meals was purely voluntary. The restriction on commissary food during RHU placement, under those circumstances, did not deny Maple “the minimal civilized measure of life’s necessities.” Subjectively, the daily provision of food and continuous medical monitoring affirmatively contradicted any allegation of deliberate indifference to Maple’s health or well-being.
Key Takeaways
- A self-imposed hunger strike does not convert routine commissary restrictions into an Eighth Amendment violation; when institutional meals are regularly offered and an inmate voluntarily declines them, the objective prong of a prison-conditions claim is not satisfied merely by the loss of commissary food supplements during RHU placement.
- DOC’s provision of daily medical monitoring for an inmate on a hunger strike affirmatively contradicts the subjective “deliberate indifference” prong of an Eighth Amendment claim, even when the inmate refuses the offered medical care.
- Policy ambiguity—here, silence in DC-ADM 815 about confiscation of already-purchased commissary items—can create a genuine issue of material fact sufficient to defeat a petitioner’s application for summary relief under Pa. R.A.P. 1532(b), even when the underlying Eighth Amendment claim is unlikely to prevail on the merits.
- Commissary purchasing restrictions applicable to Level 5 (RHU) housing do not automatically amount to a denial of “adequate food” where the prison continues to offer standard institutional meals; the distinction between restricting optional supplements and denying food is central to the Eighth Amendment analysis.
Why It Matters
Maple draws a clear line in Pennsylvania prisoner-conditions litigation: an inmate’s voluntary decision to refuse food—not the prison’s actions—is the proximate cause of any food deprivation when institutional meals are available and offered. Attorneys representing DOC or county correctional facilities should note that consistent meal offerings and documented medical monitoring are the critical facts in defeating Eighth Amendment hunger-strike claims. On the flip side, practitioners representing incarcerated individuals should recognize that commissary restrictions tied to security-level reclassification present a harder constitutional target than complete denial of food, and should focus pleading efforts on the scope and documentation of institutional meal availability and medical response protocols.
The case also has procedural significance for Commonwealth Court original-jurisdiction litigation. The court’s finding that policy silence on confiscation of pre-purchased items was sufficient to generate a genuine material fact dispute illustrates that DOC’s policies must speak clearly to each aspect of inmate property rights in order to support summary relief—whether sought by DOC or by an inmate. The underlying Eighth Amendment claim remains pending on the merits.