U.S. Court of Appeals for the Third Circuit, 1996

The court held that the alleged police conduct could support a Fourteenth Amendment substantive due process claim under the state-created danger theory, even without a custodial special relationship, and that the record presented a triable issue as to the officers.

A Third Circuit panel reversed the district court's Rule 12(b)(6) dismissal of a pro se section 1983 complaint in which protective-custody inmates at New Jersey's Wagner Youth Correctional Facility alleged cruel and unusual punishment and denial of access to the courts.