Brown v. Glover

CourtDistrict Court, M.D. Pennsylvania
DecidedJune 14, 2023
Docket4:22-cv-01154
StatusUnknown

This text of Brown v. Glover (Brown v. Glover) 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
Brown v. Glover, (M.D. Pa. 2023).

Opinion

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

TODD ALAN BROWN, No. 4:22-CV-01154

Plaintiff, (Chief Judge Brann)

v.

WARDEN GLOVER, et al.,

Defendants.

MEMORANDUM OPINION

JUNE 14, 2023 Plaintiff Todd Alan Brown is currently incarcerated in a state correctional institution. Prior to being transferred into the state prison system, he was detained at Huntingdon County Prison in Huntingdon, Pennsylvania. Brown filed the instant pro se Section 19831 action concerning alleged lack of medical care at the prison, asserting constitutional violations against various prison officials and medical staff. Brown’s initial complaint was dismissed but he was granted leave to amend. His amended complaint was partially dismissed. The two remaining medical defendants now move to dismiss the amended complaint pursuant to Federal Rule of Civil Procedure 12(b)(6).

1 42 U.S.C. § 1983. Section 1983 creates a private cause of action to redress constitutional wrongs committed by state officials. The statute is not a source of substantive rights; it serves as a mechanism for vindicating rights otherwise protected by federal law. See Gonzaga Univ. I. 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.”2 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.3 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.4 When the sufficiency of a complaint is challenged, the court must conduct a three-step inquiry.5 At step one, the court must “tak[e] note of the elements [the] plaintiff must plead to state a claim.”6 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.7 Finally, the court must review the presumed-truthful allegations “and

2 Scheuer v. Rhodes, 416 U.S. 232, 236 (1974); see Nami v. Fauver, 82 F.3d 63, 66 (3d Cir. 1996). 3 Phillips v. County of Allegheny, 515 F.3d 224, 229 (3d Cir. 2008). 4 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)). 5 Connelly v. Lane Const. Corp., 809 F.3d 780, 787 (3d Cir. 2016) (internal citations and quotation marks omitted) (footnote omitted). 6 Id. (quoting Ashcroft v. Iqbal, 556 U.S. 662, 675 (2009) (alterations in original)). 7 Id. (quoting Iqbal, 556 U.S. at 679). then determine whether they plausibly give rise to an entitlement to relief.”8 Deciding plausibility is a “context-specific task that requires the reviewing court to

draw on its judicial experience and common sense.”9 Because Brown proceeds pro se, his pleadings are to be liberally construed and his amended complaint, “however inartfully pleaded, must be held to less stringent standards than formal pleadings drafted by lawyers[.]”10 This is

particularly true when the pro se litigant, like Brown, is incarcerated.11 II. DISCUSSION In his original complaint, Brown alleged that he was involved in an incident

with police officers and suffered serious injuries from their use of excessive force, including a hematoma, facial contusion, broken left pinky finger, and concussion.12 He was hospitalized, and after his discharge on December 21, 2021, he was taken to Huntingdon County Prison and remained there until February 3, 2022.13 Brown

maintained that his medical care at the prison fell below constitutional standards.14 The Court screened Brown’s initial complaint as required by 28 U.S.C. § 1915A.15 The Court first determined that Brown had failed to allege personal

8 Id. (quoting Iqbal, 556 U.S. at 679). 9 Iqbal, 556 U.S. at 681. 10 Erickson v. Pardus, 551 U.S. 89, 94 (2007) (citations omitted). 11 Dooley v. Wetzel, 957 F.3d 366, 374 (3d Cir. 2020) (citation omitted). 12 Doc. 1 at 5. 13 Id. at 4; Doc. 11 at 1. 14 See generally Doc. 1. 15 See generally Docs. 9, 10. involvement for most of the named defendants.16 As to the two healthcare defendants, the Court found that Brown’s allegations failed to state deliberate

indifference to serious medical needs.17 Thus, the Court dismissed Brown’s complaint but granted leave to amend.18 Brown then filed an amended complaint, again raising claims under the Fourteenth Amendment19 for alleged deliberate indifference to serious medical

needs.20 The Court screened the amended complaint pursuant to Section 1915A.21 The Court again dismissed the Section 1983 claims against the non-medical defendants, as Brown had failed to establish their personal involvement in the

purported constitutional violation.22 The claims against the medical defendants— “nurse Susan” and an unidentified doctor—were permitted to proceed.23 Following identification of and service on the two healthcare defendants—

nurse Susan Watkins and Dr. Mark Minor—both Defendants filed motions to dismiss the amended complaint pursuant to Federal Rule of Civil Procedure 12(b)(6). Brown opposed Watkins’ motion24 but did not respond to or oppose Dr.

16 See Doc. 9 at 6-7. 17 See id. at 7-10. 18 Id. at 10-11. 19 Because Brown was a pretrial detainee at the time of the events, his claims implicate the Fourteenth Amendment, not the Eighth. See Jacobs v. Cumberland County, 8 F.4th 187, 193- 94 (3d Cir. 2021); Thomas v. Cumberland County, 749 F.3d 217, 223 n.4 (3d Cir. 2014). 20 See generally Doc. 11. 21 See generally Docs. 16, 17. 22 See Doc. 16 at 5-6. 23 Id. at 6-9. 24 See generally Doc. 26. Minor’s motion in any way. The time for briefing has passed, so the Rule 12(b)(6) motions are ripe for disposition.

A. Alleged Fourteenth Amendment Violation As previously noted, Brown was a pretrial detainee at the time of the relevant events, so his claims implicate the Due Process Clause of the Fourteenth

Amendment rather than the Eighth Amendment’s cruel-and-unusual-punishment provision. However, it does not appear that the United States Court of Appeals for the Third Circuit has established or adhered to a different standard with respect to Fourteenth Amendment pretrial detainee medical indifference claims versus those

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Brown v. Glover, Counsel Stack Legal Research, https://law.counselstack.com/opinion/brown-v-glover-pamd-2023.