Brown v. Jividen

CourtDistrict Court, S.D. West Virginia
DecidedMarch 31, 2025
Docket5:24-cv-00152
StatusUnknown

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

Bluebook
Brown v. Jividen, (S.D.W. Va. 2025).

Opinion

UNITED STATES DISTRICT COURT FOR THE SOUTHERN DISTRICT OF WEST VIRGINIA

AT BECKLEY

ANTHONY BROWN,

Plaintiff,

v. CIVIL ACTION NO. 5:24-cv-00152

BETSY JIVIDEN, individually as a former employee of the West Virginia Division of Corrections and Rehabilitation, and MICHAEL FRANCIS, individually as a former employee of the West Virginia Division of Corrections and Rehabilitation, and LARRY WARDEN, individually as a former employee of the West Virginia Division of Corrections and Rehabilitation, and JEFF S. SANDY, individually as a former employee of the West Virginia Department of Homeland Security, and JUSTIN MULLINS, individually as an employee of the West Virginia Division of Corrections and Rehabilitation, and MICHAEL PACK, individually as an employee of the West Virginia Division of Corrections and Rehabilitation, and JEREMY RICHMOND, individually as an employee of the West Virginia Division of Corrections and Rehabilitation, and HAROLD WITHROW, individually as an employee of the West Virginia Division of Corrections and Rehabilitation, and NICK BURTON, individually as an employee of the West Virginia Division of Corrections and Rehabilitation, and JOHN/JANE DOE CORRECTIONAL OFFICERS,

Defendants. MEMORANDUM OPINION AND ORDER

Pending are Motions to Dismiss filed by Defendant Jeff S. Sandy [ECF 28], on May 22, 2024, Defendant Betsy Jividen [ECF 31], on May 23, 2024, Defendants Michael Francis and Larry Warden [ECF 37], on July 22, 2024, and Defendants Justin Mullins, Michael Pack, Jeremy Richmond, Harold Withrow, and Nick Burton (“Officer Defendants”) [ECF 81], on September 27, 2024. Plaintiff Anthony Brown responded to each Motion [ECF 33, 34, 51, 83], to which Defendants Sandy, Francis, Warden, and the Officer Defendants filed their respective replies [ECF 35, 58, 84]. Defendant Jividen did not file a reply. The matters are ready for adjudication.

I.

In March 2022, Mr. Brown was an inmate incarcerated at Southern Regional Jail (“SRJ”). [ECF 23 at ¶ 4]. Mr. Brown alleges that while he was asleep in his cell on March 26, 2022, fellow inmates launched a “brutal and coordinated attack” on him. [Id. at ¶ 34]. He was “stabbed between 12 and 15 times with shanks.” [Id.]. The attack “lasted approximately 45 seconds and resulted in more than one dozen puncture wounds to his body.” [Id. at ¶ 47]. As a result, Mr. Brown “suffered extreme mental and emotional injury and distress in addition to physical pain and suffering and bears permanent scarring.” [Id. at ¶ 48]. Mr. Brown asserts the attack was possible due to a “defective and unsecured cell door lock,” as well as a general lack of supervision and safety checks by prison officials which allowed for freedom of movement by inmates and “availability of homemade weapons.” [Id. at ¶¶ 37, 41–42]. On March 26, 2024, Mr. Brown instituted this action against several defendants, including Defendant Jividen, the former Commissioner of the West Virginia Division of Corrections and Rehabilitation (“WVDCR”), Defendant Francis, the former Superintendent of the WVDCR, Defendant Warden, the Commanding Correctional Officer at SRJ, and Defendant Sandy, the former Cabinet Secretary of the West Virginia Department of Homeland Security. [ECF 1]. On May 9, 2024, Mr. Brown filed an Amended Complaint (“Complaint”), adding WVDCR Defendants Justin Mullins, Michael Pack, Jeremy Richmond, Harold Withrow, and Nick Burton, who were all Correctional Officers at SRJ at the time of the alleged attack. [ECF 23]. Mr. Brown

alleges the following claims: (1) Count I – “Eighth Amendment Violations under 42 U.S.C. § 1983,” (2) Count II – “Conspiracy to Committ [sic] Eighth Amendment Violations under 42 U.S.C. § 1983,” (3) Count III – “Failure to Intervene/Bystander Liability under 41 U.S.C. § 1983,” (4) Count IV – “Negligence,” (5) Count V – “Gross Negligence,” (6) Count VI – “Intentional Infliction of Emotional Distress/Tort of Outrage,” (7) Count VII – “Common Law Civil Conspiracy,” (8) Count VIII1 – “Negligent Hiring,” (9) Count IX2 – “Negligent Supervision and Training,” and (10) Count X – “Negligent Retention.” [Id. at 10–24]. Defendant Brad Douglas was voluntarily dismissed on May 23, 2024. [ECF 30]. Defendants Sandy, Jividen, Francis, Warden, and the Officer Defendants now move to dismiss the

Complaint pursuant to Federal Rule of Civil Procedure 12(b)(6). [ECF 28, 31, 37, 81].

II.

Federal Rule of Civil Procedure 8(a)(2) requires that a pleader provide “a short and plain statement of the claim showing . . . entitle[ment] to relief.” Fed. R. Civ. P. 8(a)(2); Erickson v. Pardus, 551 U.S. 89, 93 (2007). Rule 12(b)(6) correspondingly permits a defendant to challenge

1 This claim is erroneously referred to as the second of two Count VIIs in the Amended Complaint. [ECF 23 at 19]. All future references to this claim will be listed as Count VIII.

2 This claim is erroneously referred to as the first of two Count Xs in the Amended Complaint. [ECF 23 at 21]. All future references to this claim will be listed as Count IX. a complaint when it “fail[s] to state a claim upon which relief can be granted.” Fed. R. Civ. P. 12(b)(6). The required “short and plain statement” must provide “fair notice of what the . . . claim is and the grounds upon which it rests.” Bell Atl. Corp. v. Twombly, 550 U.S. 544, 555 (2007) (internal quotation marks and citation omitted); McCleary-Evans v. Md. Dep’t of Transp., State

Highway Admin., 780 F.3d 582, 585 (4th Cir. 2015). Additionally, the showing of an “entitlement to relief” amounts to “more than labels and conclusions.” Twombly, 550 U.S. at 555. It is now settled that “a formulaic recitation of the elements of a cause of action will not do.” Id.; McCleary- Evans, 780 F.3d at 585; Bing v. Brivo Sys., LLC, 959 F.3d 605, 616 (4th Cir. 2020), cert. denied, 209 L. Ed. 2d 122, 141 S. Ct. 1376 (2021); Giarratano v. Johnson, 521 F.3d 298, 304 (4th Cir. 2008). The complaint need not “forecast evidence sufficient to prove the elements of [a] claim,” but it must “allege sufficient facts to establish those elements.” Walters v. McMahen, 684 F.3d 435, 439 (4th Cir. 2012) (citing Robertson v. Sea Pines Real Est. Cos., 679 F.3d 278, 291

(4th Cir. 2012)) (internal quotation marks omitted). Stated another way, the operative pleading need only contain “[f]actual allegations . . . [sufficient] to raise a right to relief above the speculative level.” Twombly, 550 U.S. at 555; Ashcroft v. Iqbal, 556 U.S. 662, 678 (2009) (noting the opening pleading “does not require ‘detailed factual allegations,’ but it demands more than an unadorned, the-defendant-unlawfully-harmed-me accusation.”).

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Brown v. Jividen, Counsel Stack Legal Research, https://law.counselstack.com/opinion/brown-v-jividen-wvsd-2025.