Federal court dismisses Duffalo death lawsuit
Clearfield inmate died in custody in 2019
A federal lawsuit brought against Clearfield County, its Prison Board and several prison officials concerning the suicide death of an inmate that occurred in 2019 has been dismissed by U.S. District Judge Kim R. Gibson, presiding in Johnstown.
Gibson dismissed the lawsuit after receiving a petition from attorneys representing the estate of the inmate, Michael J. Duffalo, 38, who died in his cell on March 10, 2019, and Clearfield County prison personnel.
The judge earlier this month agreed to the requested dismissal, noting that it was “with prejudice,” which means the lawsuit cannot be refiled.
The lawsuit was filed two years to the day that Duffalo was found deceased in his cell.
The original lawsuit included — as defendants — officials from Jefferson County as well as Clearfield County, and the company that provided mental health services to inmates in the Clearfield County Prison, Nulton Diagnostic and Treatment Center of Johnstown.
Attorney Dylan T. Hastings of Philadelphia, representing the estate of Michael Duffalo, on July 14, filed a revised lawsuit dropping the Jefferson County officials as defendants.
He later dropped Nulton Diagnostic from the lawsuit.
In August, both sides filed extensive legal briefs.
Clearfield County, represented by Altoona attorney Mary Lou Maierhofer, asked that the lawsuit be dismissed.
In her brief, she contended the lawsuit was untimely in that it was filed beyond the statute of limitations.
She went on to claim that corrections officers named as defendants were immune from lawsuit, citing a precedential case from the 3rd U.S. Circuit Court of Appeals which concluded that it was inappropriate to place custodial officers in a position where they must guarantee an inmate does not commit suicide.
The Maierhofer brief also argued that the plaintiff could not show that Michael Duffalo’s Fourth and Eighth Amendment rights under the U.S.Constitution had been breached.
Hastings in his brief contended the lawsuit was filed within the statute of limitations and that County’s prison personnel were not immune to lawsuit, noting the county itself had “long-standing practices, customs, and/or policies… that encouraged, endorsed or permitted failure” in cases such as Duffalo’s.
Both sides appeared ready for a lengthy court battle — having rejected mediation in the case.
But midway through October, the plaintiff’s attorney sought dismissal of the federal action and was joined in that request by Maierhofer.
Hastings said that after reviewing his case against Clearfield, he concluded that proving a civil rights violation under the circumstances of the case would have been difficult.
He said it is by no means easy to prove these types of civil rights cases.
The lawsuit was filed on behalf of Mikayla Duffalo, Michael Duffalo’s daughter, who was administrator of his estate.
Mchael Duffalo was arrested on March, 4, 2019, in Jefferson County, as the result of a domestic dispute in Brockway.
The lawsuit claimed that he was suffering a breakdown and in obvious need of mental health care.
Jefferson County then released him to Clearfield County Prison after it was discovered there was a warrant for his arrest there.
A booking report showed that Michael Duffalo, a daily drug user, was crying, anxious, and worried upon arrival in Clearfield County, yet the booking officer did not believe he was at risk for suicide.
On March 10, he asked a corrections officer for a second bedsheet, and while the officer did not provide him with an extra sheet, the lawsuit claimed, as a correctional officer, he should have gone a step further and investigated why Duffalo was seeking an extra sheet.
Hastings in September filed another lawsuit against Clearfield County and its prison stemming from the death of 36-year-old Kristen E.Corson, who died after being placed in the prison in October 2019.
That lawsuit contended the inmate complained as she was being arrested by a county parole officer that she did not feel well.
She continued complaining about her health upon admission to the prison but, it was contended, she was ignored by Clearifield prison authorities.
She died of pneumonia while in prison.
Hastings said the Corson case is continuing.





