Benson Phillip Gatu Njuguna v. Rocky Holcomb, et al.

District Court, E.D. Virginia·Decided August 19, 2026·No. 1:25-cv-02384·Unknown

Opinion

UNITED STATES DISTRICT COURT FOR THE EASTERN DISTRICT OF VIRGINIA Alexandria Division

BENSON PHILLIP GATU NJUGUNA, Plaintiff, 1:25-cv-2384-MSN-WBP v.

ROCKY HOLCOMB, et al., Defendants.

MEMORANDUM OPINION Proceeding pro se, pretrial detainee Benson Phillip Gatu Njuguna (“Plaintiff”) filed this action under 42 U.S.C. § 1983. The Complaint alleges that officials at the Virginia Beach City Jail (“VBCJ”) violated his constitutional rights through deliberate indifference to his medical needs, imposing unconstitutional conditions of confinement, and unauthorized disclosure of his medical information. ECF 1. This action is before the Court on the following motions: (1) a Motion/Request for Docket Seal (ECF 4); (2) a Motion to Appoint Pro Bono Attorney (ECF 5); (3) a Motion to Proceed In Forma Pauperis (“IFP”) (ECF 6); (4) a Motion/Request to Seal Proceedings (ECF 11); (5) a Motion for Court Appointed Attorney (ECF 12); (6) a Motion to Certify Matter as Urgent (ECF 14); (7) a Motion for Discovery and Inspection (ECF 15); (8) a Motion to Certify Matter as Urgent and Seal Docket from Public (ECF 19); (9) a Motion for Discovery (ECF 18); (10) a Motion to Request for a Jury (ECF 20); (11) a Letter/Motion Requesting Court Order for U.S. Marshals to Serve Defendants (ECF 25); and (12) a Motion/Request to Add Defendant (ECF 27). As explained below, the Complaint currently fails to state a claim, and Plaintiff will be directed to amend it. The Motion to Proceed IFP will be conditionally granted, and all remaining motions will be denied. I. SCREENING UNDER 28 U.S.C. § 1915A(A) A. Background The Complaint describes several events that allegedly occurred at VBCJ in October and November of 2025. ECF 1. First, the Complaint states that when Plaintiff arrived at VBCJ, he

informed officials about his history of seizures, but they still assigned him to a top bunk. Id. at 4. Plaintiff later had a seizure while climbing to the top bunk and he fell and injured his head and hip. Id. Second, the Complaint asserts that VBCJ officials placed Plaintiff in crowded cells where he had to sleep on a mattress on the floor close to the toilet. Id. at 8. Third, the Complaint states that officials provided Plaintiff with only one jumpsuit and slip-ons when he arrived at VBCJ and told him that he would have to purchase additional clothing from the canteen. Id. at 10. Fourth, the Complaint asserts that medical staff exposed Plaintiff’s medical information that is protected under the Health Insurance Portability and Accountability Act (“HIPAA”) and the Prison Rape Elimination Act (“PREA”). Id. at 10–11. B. Section 1915A Screening Standard

Because Plaintiff is a pretrial detainee, his Complaint is subject to screening under 28 U.S.C. § 1915A(a) to determine if it is frivolous, malicious, or fails to state a claim upon which relief may be granted. 28 U.S.C. § 1915A(a), (b). The Complaint must “contain sufficient factual matter, accepted as true, to ‘state a claim to relief that is plausible on its face.’” Ashcroft v. Iqbal, 556 U.S. 662, 678 (2009) (quoting Bell Atl. Corp. v. Twombly, 550 U.S. 544, 570 (2007)). A claim has “facial plausibility when the plaintiff pleads factual content that allows the court to draw the reasonable inference that the defendant is liable for the misconduct alleged.” Owens v. Baltimore City State’s Att’ys Off., 767 F.3d 379, 388 (4th Cir. 2014) (quoting Iqbal, 550 U.S. at 678). C. Fourteenth Amendment Standard As Plaintiff is a pretrial detainee, his claims regarding the adequacy of medical attention and the conditions of his confinement are governed by the Due Process Clause of the Fourteenth Amendment. See Bell v. Wolfish, 441 U.S. 520, 535–36 (1979). The Fourteenth Amendment

“protects pretrial detainees from governmental action that is not rationally related to a legitimate nonpunitive governmental purpose or that is excessive in relation to that purpose.” Short v. Hartman, 87 F.4th 593, 608-09 (4th Cir. 2023) (cleaned up). To state a due process claim based on deliberate indifference to a medical need, a pretrial detainee must plead that they had a medical condition or injury that posed a substantial risk of serious harm; (2) the defendant intentionally, knowingly, or recklessly acted or failed to act to appropriately address the risk that the condition posed; (3) the defendant knew or should have known (a) that the detainee had that condition and (b) that the defendant’s action or inaction posed an unjustifiably high risk of harm; and (4) as a result, the detainee was harmed. Short, 87 F.4th at 611. Similarly, to state a claim for deliberate indifference based on conditions of confinement, a plaintiff must allege (1) “deprivation of a basic human need that is objectively sufficiently serious” to generate (a) “a serious or significant physical or emotional injury resulting from the challenged conditions,” or (b) “a substantial risk of such serious harm resulting from the prisoner’s unwilling exposure to the challenged conditions,” and (2) that the defendant “ acted or failed to act in the face of an unjustifiably high risk of harm that is either known or so obvious that it should be known.” Hammock v. Watts, 146 F.4th 349, 360 (4th Cir. 2025) (cleaned up). D. Individual Claims 1. Deliberate Indifference to Medical Needs The Complaint alleges that VBCJ officials were deliberately indifferent to Plaintiff’s serious medical needs in violation of the Fourteenth Amendment by assigning him to a top bunk bed after he informed officials that he has a history of seizures. Id. at 4. Plaintiff then allegedly had a seizure on November 11, 2025, while climbing to his top bunk and fell and injured his head and hip. Id. at 4–5. He did not receive medical care following the seizure. Id. at 5. The Complaint alleges that Plaintiff informed Defendants, specifically medical staff,

deputies, and a sergeant, that he has issues with short-term loss of memory, loss of concentration, and seizures (ECF at 4); however, the Complaint does not allege that Plaintiff informed Defendants that he could suffer injuries if assigned to a top bunk or that Defendants otherwise knew that he was at risk of injury from a fall. Further, the Complaint lumps multiple Defendants together and seems to assert that each had notice of his condition and caused him to be on a top bunk, but does not contain facts to support these allegations. See Wright v. Collins, 766 F.2d 841, 850 (4th Cir. 1985) (holding that to establish personal liability under § 1983, a plaintiff must “affirmatively show[] that the official charged acted personally in the deprivation of the plaintiff’s rights”). The Complaint does not identify which Defendants were responsible for Plaintiff’s bunk placement and instead states that “the facility” assigned him to a top bunk. Id. at 4. Therefore, the Complaint

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