Barton v. Bryan County Sheriff's Department

CourtDistrict Court, S.D. Georgia
DecidedAugust 14, 2025
Docket4:25-cv-00174
StatusUnknown

This text of Barton v. Bryan County Sheriff's Department (Barton v. Bryan County Sheriff's Department) is published on Counsel Stack Legal Research, covering District Court, S.D. Georgia primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Barton v. Bryan County Sheriff's Department, (S.D. Ga. 2025).

Opinion

UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF GEORGIA SAVANNAH DIVISION CHRISTOPHER EUGENE ) BARTON, ) ) Plaintiff, ) ) v. ) CV425-174 ) BRYAN COUNTY SHERIFF’S ) DEPARTMENT, ) ) Defendant. ) ORDER Pro se plaintiff Christopher Eugene Barton filed this 42 U.S.C. § 1983 case alleging that he was unjustly subjected to disciplinary restrictions by unidentified staff at the Bryan County Sheriff’s Office. See generally doc. 1. The Court granted him leave to proceed in forma pauperis and directed him to return several forms. Doc. 4. He has returned the forms. Docs. 7 & 8. The Court, therefore, proceeds to screen his Complaint. See 28 U.S.C. § 1915A. As explained below, Barton’s Complaint fails to state a claim upon which relief can be granted, and does not appear amendable. Because the Court applies Federal Rule of Civil Procedure 12(b)(6) standards in screening a complaint pursuant to § 1915A, Leal v. Ga. Dep’t of Corr., 254 F.3d 1276, 1278-79 (11th Cir. 2001), allegations in the Complaint are taken as true and construed in the light most favorable to

the plaintiff. Bumpus v. Watts, 448 F. App’x 3, 4 n.1 (11th Cir. 2011). Conclusory allegations, however, fail. Ashcroft v. Iqbal, 556 U.S. 662, 678 (2009) (discussing a Rule 12(b)(6) dismissal). As Plaintiff is proceeding

pro se, his pleadings are held to a less stringent standard than pleadings drafted by attorneys and are liberally construed. See Bingham v.

Thomas, 654 F.3d 1171, 1175 (11th Cir. 2011). Barton alleges that, on July 22, 2025, he was concerned that several other inmates did not respond when his dorm’s lights were dimmed to

indicate “lock down.” Doc. 1 at 5. Barton was concerned because their failure to respond could result in “the unit[’]s loss of privileges.” Id. After confronting the other inmates, Barton alleges that one of them attacked

him. Id. Barton returned to his cell and was locked down for the night. Id. In the morning, he was not allowed out of his cell and was informed that his restriction was the result of the altercation. Id. He alleges that

the other inmate was not disciplined because he was considered the instigator. Id. at 5-6. He alleges that he now “fear[s] for [his] own physical safety.” Id. I. Improper Defendant The first problem with Barton’s Complaint is that it fails to name

any defendant who is subject to suit. The only defendant identified is the Bryan County Sheriff’s Department, as an entity. See doc. 1 at 1, 4. In Georgia sheriffs’ departments are not proper parties to a § 1983 lawsuit

because they are not legal entities capable of being sued. See, e.g., Wooten v. Bohannon, 2021 WL 5751440, at *2 (S.D. Ga. Nov. 10, 2021) (citing

Hale v. Tallapoosa Cnty., 50 F.3d 1579, 1582 (11th Cir. 1995)) (recommending dismissal of claims against county sheriff’s department because department was “not a ‘person’ subject to suit under § 1983”),

adopted 2021 WL 5746004 (S.D. Ga. Dec. 2, 2021). Accordingly, all claims against the Bryan County Sheriff’s Office must be DISMISSED. However, as explained below, even if Barton could identify a proper

defendant, the facts alleged do not implicate any viable claim. II. Failure to Protect “[P]rison officials have a duty . . . to protect prisoners from violence

at the hands of other prisoners.” Farmer v. Brennan, 511 U.S. 825, 833 (1994) (quotes and cites omitted). However, “[p]rison officials must have been deliberately indifferent to a known danger before we can say that their failure to intervene offended ‘evolving standards of decency,’ thereby rising to the level of a constitutional tort.” Brown v. Hughes, 894

F.2d 1533, 1537 (11th Cir. 1990) (citing Estelle v. Gamble, 429 U.S. 97, 105-06 (1976)). The Eleventh Circuit has recently clarified that, to establish subjective recklessness, the plaintiff must show “that the

defendant was actually subjectively aware that his own conduct,” whether action or inaction, “caused a substantial risk of serious harm to

the plaintiff.” Wade v. McDade, 106 F.4th 1251, 1262 (11th Cir. 2024). Moreover, in the context of a failure-to-protect claim, the threat must rise to the level of “a strong likelihood, rather than a mere possibility before

a guard’s failure to act can constitute deliberate indifference.” Brown, 894 F.2d at 1537 (internal quotation marks and citation omitted). Generalized “risk” of altercations between prisoners is not sufficient. As

this Court has observed: “Prisons are dangerous places because they are filled with people society has already deemed too dangerous to live amongst law abiding persons. Prisoners will always be at some risk of

harm simply by being surrounded by these people. [Cit.] In order to trigger a failure-to-protect claim, a plaintiff must allege that the threat rose above the background danger.” Goodson v. Benton, 2020 WL 975089, at *2 (S.D. Ga. Jan. 16, 2020) (citations omitted).

Barton fails to allege any failure-to-protect claim. There is no indication that the individual with whom he argued had ever posed a threat before or, even if there were some prior indication, that any jail

staff were aware of it. Instead, it appears that the fight, which incidentally appears to have resulted in no significant injuries to either

party, was a spontaneous occurrence. As such, the facts alleged simply do not support a failure to protect claim against any possible defendant. III. Prison Discipline

Barton’s allegations concerning the slightly more restrictive conditions of confinement, i.e., “lock down,” he was subjected to after the fight also do not implicate any plausible claim. The Due Process Clause

“does not directly protect an inmate from changes in the conditions of his confinement” or create a constitutionally protected interest “‘in being confined to a general population cell, rather than the more austere and

restrictive administrative segregation quarters.’” Chandler v. Baird, 926 F.2d 1057, 1060 (11th Cir. 1991) (quoting Hewitt v. Helms, 459 U.S. 460, 466 (1983)). Generally, “[w]hen an inmate is placed in conditions more restrictive than those in the general prison population, whether through protective segregation . . . or discretionary administrative segregation, his

liberty is affected only if the more restrictive conditions are particularly harsh compared to ordinary prison life or if he remains subject to those conditions for a significantly long time.” Earl v. Racine Cty. Jail, 718 F.3d

689, 691 (7th Cir. 2013) (per curiam). Thus, to state a due process claim, a prisoner must allege more than just confinement in segregation without

due process. See Sandin v. Conner, 515 U.S. 472, 484 (1995). The prisoner must also show that the nature of his confinement (i.e., the conditions or duration) gives rise to a protected liberty interest and otherwise entitles

him to some measure of due process. See id. at 486-87.

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Related

Estelle v. Gamble
429 U.S. 97 (Supreme Court, 1976)
Hewitt v. Helms
459 U.S. 460 (Supreme Court, 1983)
Sandin v. Conner
515 U.S. 472 (Supreme Court, 1995)
Ashcroft v. Iqbal
556 U.S. 662 (Supreme Court, 2009)
Jim Eric Chandler v. Captain William Baird
926 F.2d 1057 (Eleventh Circuit, 1991)
Bingham v. Thomas
654 F.3d 1171 (Eleventh Circuit, 2011)
Sirica Bumpus v. Harrell Watts, Mr Peterson
448 F. App'x 3 (Eleventh Circuit, 2011)
Farmer v. Brennan
511 U.S. 825 (Supreme Court, 1994)
Daryise Earl v. Racine County Jail
718 F.3d 689 (Seventh Circuit, 2013)
Adrian Jenkins v. Susan M. Walker
620 F. App'x 709 (Eleventh Circuit, 2015)
Hale v. Tallapoosa County
50 F.3d 1579 (Eleventh Circuit, 1995)

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Barton v. Bryan County Sheriff's Department, Counsel Stack Legal Research, https://law.counselstack.com/opinion/barton-v-bryan-county-sheriffs-department-gasd-2025.