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Davis v. Samuels

3rd Circuit

June 11, 2020

While confined at the Moshannon Valley Correctional Center (“MVCC”), a private prison operated by The GEO Group, Inc. under contract with the Federal Bureau of Prisons, Brian Davis was denied permission to marry his fiancée, Fredricka Beckford. Davis and Beckford sued the GEO and two federal officials, asserting various state and federal law claims against the GEO and the Federal Defendants, the gravamen of which was that the Appellants were denied the right to marry due to unlawful discrimination. The Third Circuit affirmed in part and reversed in part, holding that the District Court wrongly dismissed certain claims.


The Third Circuit ruled that a basic premise of the District Court’s decision on the availability of § 1985(3) relief was erroneous. Moreover, the Court determined that the District Court abused its discretion when it, sua sonte, dismissed the claims against the Federal Defendants on the procedural ground that the Appellants had failed to properly serve them with process in accordance with Rule 4 of the Federal Rules of Civil Procedure.

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