Bennett v. Shoemaker

CourtDistrict Court, M.D. Pennsylvania
DecidedAugust 23, 2023
Docket1:22-cv-00354
StatusUnknown

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

Bluebook
Bennett v. Shoemaker, (M.D. Pa. 2023).

Opinion

IN THE UNITED STATES DISTRICT COURT FOR THE MIDDLE DISTRICT OF PENNSYLVANIA

JAMAL BENNETT, : Plaintiff : : No. 1:22-cv-0354 v. : : (Judge Rambo) BRAD SHOEMAKER and : MARK LUSK, : Defendants :

MEMORANDUM

Plaintiff Jamal Bennett initiated the above-captioned pro se action under 42 U.S.C. § 1983 regarding his pretrial detention in Lycoming County Prison (LCP). He asserts constitutional tort claims against two high-level county officials based on allegedly deficient medical care. Defendants move to dismiss Bennett’s amended complaint pursuant to Federal Rule of Civil Procedure 12(b)(6). The Court will grant Defendants’ motion. I. BACKGROUND Bennett initially filed this civil rights complaint in the Court of Common Pleas of Lycoming County, Pennsylvania, in February 2022.1 (See Doc. No. 1-2 at 3, 4.) In his original complaint, Bennett alleged that he was experiencing significant dental

1 Bennett labeled the filing a “writ of habeas corpus (for conditions of confinement).” (See Doc. No. 1-2 at 4). Bennett, however, does not seek release from detention and thus his filing does not sound in habeas corpus. See Hope v. Warden York Cnty. Prison, 972 F.3d 310, 323-25 (3d Cir. 2020) (explaining that detainees seeking “release from detention” may proceed by way of a habeas petition challenging unconstitutional conditions of confinement, but only in “extraordinary circumstances”). problems while in detention and that LCP healthcare providers were deliberately indifferent to his serious medical needs. (See Doc. No. 1-2 at 5-9 ¶¶ 5-19; id. at 14-

17 ¶¶ 32-40.) Bennett initially named two defendants: Brad Shoemaker and Mark Lusk. According to Bennett’s complaint, and confirmed by Defendants, Shoemaker is the

Warden of LCP and Lusk is the elected Sheriff of Lycoming County. (See Doc. No. 1-2 at 4, 10 ¶¶ 2, 20; Doc. No. 8 at 10.) Following receipt of a copy of the state- court complaint, Shoemaker and Lusk removed the case to this Court on March 10, 2022. (See generally Doc. No. 1.)

Shoemaker and Lusk then moved to dismiss Bennett’s complaint pursuant to Federal Rule of Civil Procedure 12(b)(6). (Doc. No. 3.) The Court granted their motion to dismiss and permitted Bennett to file an amended complaint “only to the

extent that [his amended pleading] is confined to his claims of deliberate indifference to serious medical needs” during his detention at LCP. (Doc. No. 18 at 12.) Following numerous procedural difficulties and delays caused by Bennett’s prison transfers and his repeated failure to inform the Court of his new addresses,

(see, e.g., Doc. Nos. 24, 26-28), Bennett filed an unsigned amended complaint on January 30, 2023, (see generally Doc. No. 29.) Like his original complaint, the gravamen of Bennett’s amended complaint is that he was allegedly provided

inadequate dental care while in pretrial detention at LCP. (See id. at 2-5.) In addition to Shoemaker and Lusk, Bennett names seven additional defendants: Nancy L. Butts, Kristin Rogers, Ryan Gardner, Maelynn Murphy, Andrea Hoover, Shawn P.

McGlaughlin, and Evangelical Medical Services Organization. (See id. at 2.) None of these new defendants has been served, and therefore they are currently not parties to this litigation. (See Doc. Nos. 39, 41, 42, 44-47.)

In his amended complaint, Bennett appears to assert two constitutional tort claims: (1) Fourteenth Amendment2 deliberate indifference to serious medical needs, (see Doc. No. 29 at 5-6); and (2) conspiracy to interfere with civil rights under 42 U.S.C. § 1985, (see Doc. No. 29 at 10-14.) Bennett includes an additional “count”

for “supervisor liability,” (see id. at 6-7), but—as the name suggests—this is a theory of liability for the medical indifference claim, not a separate constitutional tort. He seeks compensatory damages, punitive damages, and attorney fees and costs. (Id. at

15.) Shoemaker and Lusk (collectively “Defendants”) again move to dismiss all claims against them pursuant to Federal Rule of Civil Procedure 12(b)(6). The motion is fully briefed and ripe for disposition.

2 Because Bennett was a pretrial detainee during the events at issue, any such deficient medical care claim would fall under the Due Process Clause of the Fourteenth Amendment, rather than the Eighth Amendment. See Hubbard v. Taylor, 538 F.3d 229, 231 (3d Cir. 2008) (Hubbard II) (citing Bell v. Wolfish, 441 U.S. 520, 535 (1979)); Hubbard v. Taylor, 399 F.3d 150, 164 (3d Cir. 2005) (Hubbard I). Bennett likewise cites the Fourteenth Amendment’s Due Process Clause. (See Doc. No. 29 at 5.) II. STANDARD OF REVIEW In deciding a Rule 12(b)(6) motion to dismiss, courts should not inquire

“whether a plaintiff will ultimately prevail but whether the claimant is entitled to offer evidence to support the claims.” Scheuer v. Rhodes, 416 U.S. 232, 236 (1974); see Nami v. Fauver, 82 F.3d 63, 66 (3d Cir. 1996). The court must accept as true

the factual allegations in the complaint and draw all reasonable inferences from them in the light most favorable to the plaintiff. See Phillips v. County of Allegheny, 515 F.3d 224, 229 (3d Cir. 2008). In addition to the facts alleged on the face of the complaint, the court may also consider “exhibits attached to the complaint, matters

of public record, as well as undisputedly authentic documents” attached to a defendant’s motion to dismiss if the plaintiff’s claims are based upon these documents. Mayer v. Belichick, 605 F.3d 223, 230 (3d Cir. 2010) (citing Pension

Benefit Guar. Corp. v. White Consol. Indus., 998 F.2d 1192, 1196 (3d Cir. 1993)). When the sufficiency of a complaint is challenged, the court must conduct a three-step inquiry. See Connelly v. Lane Const. Corp., 809 F.3d 780, 787 (3d Cir. 2016) (internal citations and quotation marks omitted) (footnote omitted). At step

one, the court must “tak[e] note of the elements [the] plaintiff must plead to state a claim.” Id. (quoting Ashcroft v. Iqbal, 556 U.S. 662, 675 (2009) (alterations in original)). Second, the court should distinguish well-pleaded factual allegations—

which must be taken as true—from mere legal conclusions, which “are not entitled to the assumption of truth” and may be disregarded. Id. (quoting Iqbal, 556 U.S. at 679). Finally, the court must review the presumed-truthful allegations “and then

determine whether they plausibly give rise to an entitlement to relief.” Id. (quoting Iqbal, 556 U.S. at 679). Deciding plausibility is a “context-specific task that requires the reviewing court to draw on its judicial experience and common sense.” Iqbal,

556 U.S. at 681.

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Bennett v. Shoemaker, Counsel Stack Legal Research, https://law.counselstack.com/opinion/bennett-v-shoemaker-pamd-2023.