Rodney Anderson v. Kevin Kauffman

── Rodney Anderson v. Kevin Kauffman ── Court: Court of Appeals for the Third Circuit Date: May 19, 2026 Category: General NOT PRECEDENTIAL UNITED STATES COURT OF APPEALS FOR THE THIRD CIRCUIT ___________ No. 24-2932 ___________ RODNEY ANDERSON, Appellant v. KEVIN KAUFFMAN, Superintendent of SCI-Huntingdon; MS. C. NERI, Psychologist Department at SCI-Huntingdon; MS. COUSINS, Psychiatrist of SCI-Huntingdon ____________________________________ On Appeal from the United States District Court for the Middle District of Pennsylvania (D.C. Civil Action No. 1:22-cv-00226) District Judge: Honorable Jennifer P. Wilson ____________________________________ Submitted Pursuant to Third Circuit LAR 34.1(a) January 7, 2026 Before: HARDIMAN, FREEMAN, and ROTH, Circuit Judges (Opinion filed: May 19, 2026) _________ OPINION * _________ * This disposition is not an opinion of the full Court and pursuant to I.O.P. 5.7 does not constitute binding precedent. PER CURIAM Rodney Anderson appeals following the District Court’s entry of summary judgment in favor of the defendants remaining at that time. We will affirm the entry of summary judgment, but we will vacate in part the court’s earlier order dismissing some of Anderson’s other claims and remand for further proceedings. I. Anderson is a Pennsylvania prisoner. He filed this civil action pro se under 42 U.S.C. § 1983 and asserted numerous claims regarding his treatment at SCI-Huntingdon. His first category of claims related to his mental-health treatment during the first five months of the COVID-19 pandemic. His other claims concerned numerous other matters, including the heat and lighting in his cell, his access to the law library, his mail, and issues regarding his prison employment. Defendant Cousins, whom Anderson named as a defendant only on his mental- health claims, filed a motion to dismiss the claims against her. The remaining 12 defendants (the “DOC defendants”) filed a motion to dismiss the claims against them too. The DOC defendants sought dismissal solely on the merits and did not argue that Anderson had improperly joined his claims in a single suit. The District Court nevertheless held that Anderson had improperly joined his claims. The court sua sponte limited the case to his mental-health claims, and it dismissed all of his other claims without prejudice to his ability to raise them in a separate suit (which he has not done). The court also dismissed his mental-health 2 claims on the merits but with leave to amend as to those claims only. Anderson then filed an amended complaint limited to his mental-health claims against Cousins, C. Neri, and Kevin Kauffman. On Cousins’s motion, the court dismissed Anderson’s claims against her with prejudice. Kauffman and Neri waived their right to reply to the complaint pursuant to 42 U.S.C. § 1997e(g), and they and Anderson later filed cross-motions for summary judgment. The court denied Anderson’s motion but granted Kauffman’s and Neri’s motion and entered judgment in their favor. Anderson appeals. We have jurisdiction under 28 U.S.C. § 1291. II. Anderson raises three challenges that we will address. The first two lack merit, but the third requires remand.