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, David O’Neal, the Northeast Regional Director for the Department of Homeland Security, asserting various state and federal law claims against the GEO and the Federal Defendants, the gravamen of which is that Appellants were denied the right to marry because of unlawful discrimination. The Court of the Third Circuit affirmed in part and reversed in part, holding that the District Court wrongly dismissed certain claims.
The Court 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.