Brayboy v. Department of Corrections

CourtDistrict Court, M.D. Pennsylvania
DecidedFebruary 22, 2024
Docket3:24-cv-00009
StatusUnknown

This text of Brayboy v. Department of Corrections (Brayboy v. Department of Corrections) 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
Brayboy v. Department of Corrections, (M.D. Pa. 2024).

Opinion

| IN THE UNITED STATES DISTRICT COURT | FOR THE MIDDLE DISTRICT OF PENNSYLVANIA RODRICK MAURICE BRAYBOY, : No. 3:24-CV-0009 | Plaintiff : | : (Judge Munley) : |UNIT MANAGER HEENAN, et al., _: | Defendants :

MEMORANDUM Plaintiff Rodrick Maurice Brayboy initiated the above-captioned pro se | action under 42 U.S.C. § 1983,' alleging an Eighth Amendment violation by a prison official at the State Correctional Institution, Mahanoy (SCI Mahanoy), in | Frackville, Pennsylvania. The court will dismiss Brayboy’s complaint pursuant to 28 U.S.C. § 1915A(b)(1) for failure to state a claim upon which relief may be | granted but will provide leave to amend. |. | BACKGROUND | Brayboy alleges that on the morning of November 13, 2022, he was attacked—without provocation—by his cellmate. (See Doc. 1 at 4, 5). Brayboy | asserts that his cellmate had “mental issues,” was “paranoid,” and was also a | “karate expert.” (Id.) According to Brayboy, the attack was serious and he had 1 Section 1983 creates a private cause of action to redress constitutional wrongs committed b\ | state officials. The statute is not a source of substantive rights; it serves as a mechanism fo | vindicating rights otherwise protected by federal law. See Gonzaga Univ. v. Doe, 536 U.S. 273 | 284-85 (2002).

to be taken to the hospital. (!d.) He suffered a fractured nose, two black eyes, swelling, and a lacerated lip. (Id.) Although Brayboy’s complaint is not entirely clear, it appears that he is contending that an SCI Mahanoy official failed to protect him from the attack. (See id. at 3). Brayboy sues “Unit Manager Heenan” and the Pennsylvania Department of Corrections (DOC). (Id. at 1, 2). He seeks compensatory and punitive damages. (Id. at 5). Brayboy, however, fails to state a claim upon whicl relief may be granted, so the court will dismiss his complaint. | ll. STANDARD OF REVIEW Courts are statutorily obligated to review, “as soon as practicable,” unrepresented prisoner complaints targeting governmental entities, officers, or employees. See 28 U.S.C. § 1915A(a). One basis for dismissal at the screening | stage is if the complaint “fails to state a claim upon which relief may be granted[.]” Id. § 1915A(b)(1). This language closely tracks Federal Rule of Civil | Procedure 12(b)(6). Accordingly, courts apply the same standard to screening a

pro se prisoner complaint for sufficiency under Section 1915A(b)(1) as they utilize when resolving a motion to dismiss under Rule 12(b)(6). See Graysaii v. Mayview State Hosp., 293 F.3d 103, 109-10 & n.11 (3d Cir. 2002); O'Briat v. Fed. Gov' 763 F. App’x 157, 159 & n.5 (3d Cir. 2019) (per curiam) (nonprecedential); cf. Allah v. Seiverling, 229 F.3d 220, 223 (3d Cir. 2000).

| 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 □ | three-step inquiry. See Connelly v. Lane Const. Corp., 809 F.3d 780, 787 (3d Cir. 2016) (internal citations, quotation marks, and 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. !d. (quoting Iqbal, 556 U.S. at 679). Finally, the court must review the presumed-truthful allegation:

| “and then determine whether they plausibly give rise to an entitlement to relief.” ia. (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. | Because Brayboy proceeds pro se, his pleadings are to be liberally | construed and his complaint, “however inartfully pleaded, must be held to less stringent standards than formal pleadings drafted by lawyersj[.]” Erickson v. Paras, 551 U.S. 89, 94 (2007) (citations omitted). This is particularly true when | the pro se litigant, like Brayboy, is incarcerated. See Dooley v. Wetzel, 957 F.3d 366, 374 (3d Cir. 2020) (citation omitted). lll. DISCUSSION Before addressing the sufficiency of Brayboy’s complaint, the Court must identify the claimed constitutional violation or violations. See Albright v. Oliver, 510 U.S. 266, 271 (1994) (“The first step in any [Section 1983] claim is to identify the specific constitutional right allegedly infringed.”); Graham v. Connor, □□□ □□□ 386, 394 (1989) (explaining that analysis of a Section 1983 claim requires “identifying the specific constitutional right allegedly infringed by the challenged” conduct). Brayboy cites the Eighth and Fourteenth Amendments and utilizes the

| phrase “deliberate indifference.” (See Doc. 1 at 3). Thus, as best the court can ascertain, Brayboy is asserting a failure-to-protect claim under the Eighth Amendment as applied to the states through the Fourteenth Amendment.? Brayboy’s Section 1983 claim is deficient for multiple reasons. A. Personal Involvement It is well established that, in Section 1983 actions, liability cannot be | “predicated solely on the operation of respondeat superior.” Rode v. Dellarciprete, 845 F.2d 1195, 1207 (3d Cir. 1988) (citations omitted): see also Ashcroft v. Iqbal, 556. U.S. 662, 676 (2009) (affirming same principle in Bivens context). Rather, a Section 1983 plaintiff must plausibly plead facts that demonstrate the defendant’s “personal involvement in the alleged misconduct.” Dooley v. Wetzel, 957 F.3d 366, 374 (3d Cir. 2020). Personal involvement can include direct wrongful conduct by a defendant, but it can also be demonstrated

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Related

Scheuer v. Rhodes
416 U.S. 232 (Supreme Court, 1974)
Imbler v. Pachtman
424 U.S. 409 (Supreme Court, 1976)
Will v. Michigan Department of State Police
491 U.S. 58 (Supreme Court, 1989)
Albright v. Oliver
510 U.S. 266 (Supreme Court, 1994)
Gonzaga University v. Doe
536 U.S. 273 (Supreme Court, 2002)
Erickson v. Pardus
551 U.S. 89 (Supreme Court, 2007)
Ashcroft v. Iqbal
556 U.S. 662 (Supreme Court, 2009)
Mayer v. Belichick
605 F.3d 223 (Third Circuit, 2010)
Centifanti v. Nix
865 F.2d 1422 (Third Circuit, 1989)
Rehberg v. Paulk
132 S. Ct. 1497 (Supreme Court, 2012)
Nami v. Fauver
82 F.3d 63 (Third Circuit, 1996)
Peter Bistrian v. Troy Levi
696 F.3d 352 (Third Circuit, 2012)
Farmer v. Brennan
511 U.S. 825 (Supreme Court, 1994)
Phillips v. County of Allegheny
515 F.3d 224 (Third Circuit, 2008)
Allah v. Seiverling
229 F.3d 220 (Third Circuit, 2000)

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Brayboy v. Department of Corrections, Counsel Stack Legal Research, https://law.counselstack.com/opinion/brayboy-v-department-of-corrections-pamd-2024.