Bennett v. Washington

CourtDistrict Court, W.D. Kentucky
DecidedMarch 13, 2025
Docket4:23-cv-00126
StatusUnknown

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

Bluebook
Bennett v. Washington, (W.D. Ky. 2025).

Opinion

UNITED STATES DISTRICT COURT WESTERN DISTRICT OF KENTUCKY OWENSBORO DIVISION

KEVIN BENNETT PLAINTIFF

v. CIVIL ACTION NO. 4:23-CV-00126-JHM

ROY WASHINGTON, et al. DEFENDANTS

MEMORANDUM OPINION AND ORDER This matter is before the Court on a motion by Defendants Gary Skaggs, Roy Washington, and Grayson County for summary judgment pursuant to Federal Rule of Civil Procedure 56. [DN 68]. Plaintiff Kevin Bennett filed a response. [DN 75]. Defendants did not file a reply. Recently, Plaintiff filed a motion for the Court to take notice that the summary judgment motion was ripe for decision. [DN 79]. Fully briefed, these matters are ripe for decision. I. BACKGROUND Plaintiff filed the instant pro se action under 42 U.S.C. § 1983 against Grayson County Detention Center (“GCDC”) APRN Roy Washington, GCDC Medical Director Gary Skaggs, and United States Marshals Service (“USMS”) Deputy Greg Thiel in their individual and official capacities. [DN 1]. At the time he filed his complaint, Plaintiff was a federal pretrial detainee incarcerated at GCDC. Plaintiff brought claims against these Defendants for deliberate indifference to his serious medical needs in violation of the Fifth, Eighth, and Fourteenth Amendments to the United States Constitution. At the time he initiated this action, Plaintiff also filed a motion for a temporary restraining order and a preliminary injunction. [Id.] The Court conducted an initial review of the complaint pursuant to 28 U.S.C. § 1915A, dismissed Plaintiff’s Eighth Amendment claims, and allowed his Fifth and Fourteenth Amendment claims to proceed against Washington, Skaggs, Thiel, Grayson County, and the USMS. [DN 8]. The Court also ordered Defendants to respond to Plaintiff’s motion for a preliminary injunction. The record reflects that Plaintiff was sentenced in his federal criminal case on December 19, 2023. United States v. Bennett, No. 1:21-CR-185-SEB-DML, DN 82 (S.D. Ind. 2023). On January 24, 2024, Plaintiff was transferred to the custody of the Marion County (Indiana) Jail on the execution of an Indiana state warrant. [DN 24, DN 25]. Because Plaintiff was no longer held in the GCDC or in the USMS’s custody, the Court denied as moot Plaintiff’s motion for a temporary restraining order and a preliminary injunction. [DN 26]. On February 5, 2024, Defendants the USMS and Deputy Thiel moved to dismiss the

complaint against them pursuant to Federal Rule of Civil Procedure 12(b)(6). [DN 27, DN 28]. The Court granted their motions finding that a Fifth Amendment deliberate indifference claim is not cognizable under Bivens v. Six Unknown Named Federal Agents of Federal Bureau of Narcotics, 403 U.S. 388 (1971). [DN 56]. Defendants Grayson County, Washington, and Skaggs now move for summary judgment on Plaintiff’s remaining claims. [DN 68]. II. STANDARD OF REVIEW Before the Court may grant a motion for summary judgment, it must find that there is no genuine dispute as to any material fact and that the moving party is entitled to judgment as a matter of law. Fed. R. Civ. P. 56(a). The moving party bears the initial burden of specifying the basis for

its motion and identifying that portion of the record that demonstrates the absence of a genuine issue of material fact. Celotex Corp. v. Catrett, 477 U.S. 317, 322 (1986). Once the moving party satisfies this burden, the non-moving party thereafter must produce specific facts demonstrating a genuine issue of fact for trial. Anderson v. Liberty Lobby, Inc., 477 U.S. 242, 247–48 (1986). Although the Court must review the evidence in the light most favorable to the non-moving party, the non-movant must do more than merely show that there is some “metaphysical doubt as to 2 the material facts.” Matsushita Elec. Indus. Co. v. Zenith Radio Corp., 475 U.S. 574, 586 (1986). Instead, the Federal Rules of Civil Procedure require the non-moving party to present specific facts showing that a genuine factual issue exists by “citing to particular parts of materials in the record” or by “showing that the materials cited do not establish the absence . . . of a genuine dispute[.]” Fed. R. Civ. P. 56(c)(1). “The mere existence of a scintilla of evidence in support of the [non-moving party’s] position will be insufficient; there must be evidence on which the jury could reasonably find for the [non-movant].” Anderson, 477 U.S. at 252.

The fact that a plaintiff is pro se does not lessen his obligations under Rule 56. “The liberal treatment of pro se pleadings does not require the lenient treatment of substantive law, and the liberal standards that apply at the pleading stage do not apply after a case has progressed to the summary judgment stage.” Johnson v. Stewart, No. 08-1521, 2010 WL 8738105, at *3 (6th Cir. May 5, 2010) (citations omitted). When opposing summary judgment, a party cannot rely on allegations or denials in unsworn filings, and a party’s “status as a pro se litigant does not alter his duty on a summary judgment motion.” Viergutz v. Lucent Techs., Inc., 375 F. App’x 482, 485 (6th Cir. 2010). However, statements in a verified complaint that are based on personal knowledge may function as the equivalent of affidavit statements for purposes of summary judgment. Weberg v. Franks, 229 F.3d 514, 526 n.13 (6th Cir. 2000); Williams v. Browman, 981 F.2d 901, 905 (6th Cir. 1992); 28

U.S.C. § 1746. III. DISCUSSION Section 1983 creates no substantive rights but merely provides remedies for deprivations of rights established elsewhere. Flint ex rel. Flint v. Ky. Dep’t of Corr., 270 F.3d 340, 351 (6th Cir. 2001). Two elements are required to state a claim under § 1983. Gomez v. Toledo, 446 U.S. 635, 640 (1980). “[A] plaintiff must allege the violation of a right secured by the Constitution and laws 3 of the United States, and must show that the alleged deprivation was committed by a person acting under color of state law.” West v. Atkins, 487 U.S. 42, 48 (1988). “Absent either element, a section 1983 claim will not lie.” Christy v. Randlett, 932 F.2d 502, 504 (6th Cir. 1991). Plaintiff asserts Fourteenth Amendment deliberate indifference claims against Defendants Skaggs, Washington, and Grayson County for their alleged treatment of his testicular cyst and failure to treat his mental illnesses.

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Bennett v. Washington, Counsel Stack Legal Research, https://law.counselstack.com/opinion/bennett-v-washington-kywd-2025.