Abrams v. Paul, Warden

CourtDistrict Court, E.D. Kentucky
DecidedAugust 22, 2025
Docket5:25-cv-00285
StatusUnknown

This text of Abrams v. Paul, Warden (Abrams v. Paul, Warden) is published on Counsel Stack Legal Research, covering District Court, E.D. Kentucky primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Abrams v. Paul, Warden, (E.D. Ky. 2025).

Opinion

UNITED STATES DISTRICT COURT EASTERN DISTRICT OF KENTUCKY CENTRAL DIVISION LEXINGTON

JAMES P. ABRAMS, ) ) Plaintiff, ) Civil No. 5:25-cv-00285-GFVT ) v. ) ) MEMORANDUM OPINION DAVID PAUL, WARDEN, et al., ) & ) ORDER Defendants. )

*** *** *** *** James P. Abrams is a convicted prisoner who is currently housed at the Federal Medical Center in Lexington, Kentucky (“FMC Lexington”). Proceeding without counsel, Abrams filed a Bivens complaint against various officials at FMC Lexington. [R. 1.] Abrams also filed a motion for leave to proceed in forma pauperis. [R. 2.] Having reviewed Abrams’s motion and supporting financial documentation, the Court is persuaded that he lacks sufficient resources to pay the $350.00 filing fee up front. Accordingly, his fee-related motion will be granted and he will be permitted to pay the filing fee in installments as outlined in 28 U.S.C. § 1915(b). The Court must perform an initial review of Abrams’s complaint pursuant to 28 U.S.C. §§ 1915(e)(2) and 1915A. These provisions require dismissal of any claim that is frivolous, malicious, fails to state a claim upon which relief can be granted, or seeks monetary relief from a defendant who is immune from such relief. Abrams names six defendants in his complaint: (1) David Paul, Warden; (2) J. Sizemore, Assistant Warden; (3) Dr. Melendez, Chief Medical Officer; (4) Ms. S. Mattingly, Healthcare Unit Manager; (5) Correctional Officer Vago; and (6) unidentified Swanson Security Agency employees. Construing Abrams’s complaint liberally, he alleges that the defendants used excessive force against him and were deliberately indifferent to his serious medical needs in violation of the Eighth Amendment to the United States Constitution. For relief, he seeks monetary damages and transfer to home confinement. As an initial matter, Abrams’s demand for transfer to home confinement will be denied. “When a court sentences a federal offender, the [Bureau of Prisons] has plenary control, subject

to statutory constraints, over ‘the place of the prisoner’s imprisonment,’ and the treatment programs (if any) in which he may participate.” Tapia v. United States, 564 U.S. 319, 331 (2011) (citing 18 U.S.C. §§ 3621(b), (e), (f); 3624(f); 28 C.F.R. pt. 544 (2010)). Moreover, the BOP’s placement decisions, including determinations regarding home confinement, are expressly insulated from judicial review, as the provisions of the Administrative Procedures Act (“APA”) do not apply to such decisions. 18 U.S.C. § 3625 (“The provisions of sections 554 and 555 and 701 through 706 of title 5, United States Code, do not apply to the making of any determination, decision, or order under this subchapter.”). Cf. Woodard v. Quintana, No. 5:15- cv-307-KKC, 2015 WL 7185478, at *5-6 (E.D. Ky. Nov. 13, 2015). Turning to Abrams’s claims for money damages, constitutional claims against individual

federal employees are brought pursuant to the doctrine of Bivens, which held that an individual may “recover money damages for any injuries . . . suffered as a result of [federal] agents’ violation of his constitutional rights.” Bivens v. Six Unknown Named Agents, 403 U.S. 388, 397 (1971). But while Bivens expressly validated the availability of a claim for damages against a federal official in his or her individual capacity, an officer is only responsible for his or her own conduct. Ashcroft v. Iqbal, 556 U.S. 662, 676-677 (2009). See also Ziglar v. Abbasi, 582 U.S. 120, 140-41 (2017). Thus, a plaintiff must “plead that each Government-official defendant, through the official’s own individual actions, has violated the Constitution.” Iqbal, 556 U.S. at 676. Indeed, “[e]ven a pro se prisoner must link his allegations to material facts . . . and indicate what each defendant did to violate his rights . . . .” Sampson v. Garrett, 917 F.3d 880, 882 (6th Cir. 2019) (citing Lanman v. Hinson, 529 F.3d 673, 684 (6th Cir. 2008)). Abrams’s claims against Warden Paul must be dismissed. Although Abrams alleges the existence of poor prison conditions, he does not allege any facts indicating that Paul was actively

involved in establishing those conditions or that he had any involvement in the events leading to Abrams’s alleged harm. See Heyerman v. Cnty. of Calhoun, 680 F.3d 642, 676 (6th Cir. 2012) (observing that supervisory officials “are not liable in their individual capacities unless they ‘either encouraged the specific incident of misconduct or in some other way directly participated in it’”) (quoting Hayes v. Jefferson Cnty., 668 F.2d 869, 874 (6th Cir. 1982). Abrams’s claims against Dr. Melendez also must be dismissed. Abrams alleges that, on March 4, 2025, Melendez had him moved “off F4 Nursing Critical Care (NCC) . . . on the night before an official BOP & Department of Justice review . . . in retaliation for [Abrams] refusing to sign a waiver of liability about the repeated shackling.” [R. 1-1 at 4]. Assuming Abrams’s allegations are true, Abrams does not allege any facts indicating that he needed to remain in the

critical care unit or that moving him to a different unit constituted deliberate indifference to a serious medical condition. See Rhinehart v. Scutt, 894 F.3d 721, 738-40 (6th Cir. 2018) (explaining that to be liable for deliberate indifference, “[t]he doctor must have ‘consciously expos[ed] the patient to an excessive risk of serious harm’”) (quoting Richmond v. Huq, 885 F.3d 928, 940 (6th Cir. 2018), abrogated on other grounds by Brawner v. Scott Cnty., 14 F.4th 585, 591-97 (6th Cir. 2021)). Finally, the Court will dismiss Abrams’s claims against C.O. Vago. Abrams alleges that after he pressed the emergency button in the special housing unit (“SHU”) on April 15, 2025, Vago told him: “If you press that button you better be on the ground [expletive] dying.” [R. 1-1 at 5]. But Abrams does not allege any facts indicating that Vago was deliberately indifferent to a serious medical need when he made this statement. And verbal abuse, without more, does not constitute cruel and unusual punishment. Wingo v. Tenn. Dep’t of Corr., 499 F. App’x 453, 455 (6th Cir. 2012) (“Verbal harassment or idle threats by a state actor do not create a constitutional

violation and are insufficient to support a section 1983 claim for relief.”); Johnson v. Unknown Dellatifa, 357 F.3d 539, 546 (6th Cir. 2004) (holding “harassment and verbal abuse . . .

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Related

Ashcroft v. Iqbal
556 U.S. 662 (Supreme Court, 2009)
Tapia v. United States
131 S. Ct. 2382 (Supreme Court, 2011)
Sammie G. Byrd v. Michael P.W. Stone
94 F.3d 217 (Sixth Circuit, 1996)
Denius v. Dunlap
330 F.3d 919 (Seventh Circuit, 2003)
Heyerman v. County of Calhoun
680 F.3d 642 (Sixth Circuit, 2012)
Darrell Wingo v. Tennessee Department of Corrections
499 F. App'x 453 (Sixth Circuit, 2012)
Sigler v. American Honda Motor Co.
532 F.3d 469 (Sixth Circuit, 2008)
Lanman v. Hinson
529 F.3d 673 (Sixth Circuit, 2008)
Ziglar v. Abbasi
582 U.S. 120 (Supreme Court, 2017)
Melisa Richmond v. Rubab Huq
885 F.3d 928 (Sixth Circuit, 2018)
Lewis Rhinehart v. Debra Scutt
894 F.3d 721 (Sixth Circuit, 2018)
Timothy Sampson v. Cathy Garrett
917 F.3d 880 (Sixth Circuit, 2019)
Tammy Brawner v. Scott Cnty., Tenn.
14 F.4th 585 (Sixth Circuit, 2021)
Donaldson v. United States
35 F. App'x 184 (Sixth Circuit, 2002)

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