Since we hope to follow the progress of this suit, we want to give you an idea of what's in the Complaint, or the first document which starts the suit, but we want to do it briefly. The Complaint was filed in the Court Of Common Pleas of Huntingdon County and called Feigley et al. v Shultzaberger et al. It charges that various members of the staff at SCI-Smithfield violated the Pennsylvania and the United States Constitutions and also that they violated a number of Pennsylvania laws.

Both Sandra Feigley and her imprisoned husband, George, are the plaintiffs. There are 16 defendants: the prison's Superintendent, James Morgan and his Administrative Assistant, Sharon Burks; guards Samuel Shultzaberger, Scott Ward, Mark Price, Todd Carini, Scott Bowman and Nipps; guard sergeant Timothy Shetrom; guard lieutenants Lear and John Kaminsky; guard captain Robert Glenny; a library assistant, Jeannette Stennett; the school principal, Geoffrey Lucas; the mailroom supervisor, Scott Sieberling; and the health care administrator from SCI-Huntingdon, Patricia Yargar.

The Complaint consists of 19 separate counts. We start by explaining that the prison was designed and built to house about 500 short-term, low risk prisoners, but that now it houses about 1300 mostly young, aggressive long-term prisoners. In the first count we explain that at SCI-Smithfield two prisoners occupy each cell. They must spend over 18 hours a day in the cells, but the cells are so tiny that each man has only 13.6 square feet of space, an area the size of a piece of poster board 44 inches on a side!

The second count explains that the air quality is very bad because the cell blocks are sealed and filthy, fume laden air is repeatedly re-circulated.

The third count is that the electronic devices to unlock cell and cell block doors in the event of a fire, riot, medical emergency and so forth have repeatedly failed.

The fourth count is that the noise in the cells, cell blocks and mess hall is so intense that it is physically damaging.

In count five we describe the dangerous and deteriorated condition of the walk ways which interconnect the various prison buildings.

Count six is about the effects of the gross overcrowding of each of the prison's facilities from medical department and visiting room to the school and recreation yard.

In count seven we allege a number of serious violations of the Pennsylvania Fire and Panic Act which threaten both prisoners and staff.

Count eight details some of the many violations in the prison law library from the inadequacies of the collection to the conduct of a library assistant.

In count nine we detail practices where the staff reads legal papers, obstructs access to the courts and censors photocopying.

Count ten is about the filthy mess hall and food.

In count eleven, we plead the deficiencies in the prison school and the overt hostility which the staff and the whole Department Of Corrections has to learning and knowledge. They even restrict to only 10 the number of books that a prisoner may possess.

Count number twelve is about the scarcity of prison jobs and job training. Almost all the prisoners learn nothing except how to mop and busboy.

Count thirteen is about the fees gouged from prisoners for essential medical care and medications; a true disgrace for a civilized society - but this is Ridge's Pennsylvania, isn't it?

In count fourteen we explain how the so-called Inmate Grievance System is manipulated in order to frustrate solution of prison problems and to actually obstruct prisoners from trying to bring their grievances into court.

Count fifteen covers some of the abuses of the prison mail system. All sorts of incoming mail is simply taken for no good reason and no one is even given notice that their letters or magazines have been trashed.

In count sixteen, we present some of the abuses of the monopoly telephone system which prisoners' families must use to talk to their imprisoned loved ones. The fees are enormous: $4.84 just to connect a call and then 59 cents a minute to talk! That's $13.10 for a 15 minute call. It's cheaper to phone China!

In count seventeen we elaborate on the practice at SCI-Smithfield of guards and staff inventing rules which conflict with the rules issued by the department.

In the lengthy count eighteen we detail some of the abuses of individual guards who use searches and the seizing of prisoners' property as a means of punishment and to thwart legal activity. We also explain about two callous guards who entertain themselves with terrifying and trying to kill older prisoners.

In the last count of the Complaint we bring all the individual parts of the action together asserting that when taken as a whole, the conditions of confinement at SCI-Smithfield amount to cruel punishment.

The suit asks for damages and an injunction to stop the abuses and to provide adequate living space for each prisoner. One of the points of the suit is that some of the abuses inflicted on George Feigley were in retaliation for his writing for this website and for his prison litigation.

As the officials and the Department of Corrections try to slither out of responsibility for their conduct (and they have some of the slimiest lawyers in state government), we'll try to keep you abreast of what's happening.