Brown v. Missouri Department of Corrections

CourtDistrict Court, E.D. Missouri
DecidedFebruary 28, 2022
Docket2:21-cv-00078
StatusUnknown

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

Bluebook
Brown v. Missouri Department of Corrections, (E.D. Mo. 2022).

Opinion

UNITED STATES DISTRICT COURT EASTERN DISTRICT OF MISSOURI NORTHERN DIVISION

BARRY BROWN, ) ) Plaintiff, ) ) v. ) No. 2:21-CV-78-RWS ) MISSOURI DEPARTMENT OF ) CORRECTIONS, et al., ) ) Defendants. )

MEMORANDUM AND ORDER

This matter is before the Court upon review of a complaint filed by plaintiff Barry Brown, a prisoner. For the reasons discussed below, the Court will give plaintiff the opportunity to file an amended complaint, and will deny without prejudice plaintiff’s motion to appoint counsel. Legal Standard on Initial Review Pursuant to 28 U.S.C. § 1915A(a), this Court “shall review before docketing if feasible or, in any event, as soon as practicable after docketing, a complaint in a civil action in which a prisoner seeks redress from a governmental entity or officer or employee of a governmental entity.” Upon such review, this Court shall dismiss the complaint or any portion thereof if it is frivolous, malicious, or fails to state a claim upon which relief may be granted. 28 U.S.C. § 1915A(b)(1). An action is frivolous if it “lacks an arguable basis in either law or fact.” Neitzke v. Williams, 490 U.S. 319, 328 (1989). An action fails to state a claim upon which relief may be granted if it does not plead “enough facts to state a claim to relief that is plausible on its face.” Bell Atlantic Corp. v. Twombly, 550 U.S. 544, 570 (2007). A claim is facially plausible when the plaintiff “pleads factual content that allows the court to draw the reasonable inference that the defendant is liable for the misconduct alleged.” Ashcroft v. Iqbal, 556 U.S. 662, 678 (2009). Although a plaintiff need not allege facts in painstaking detail, the facts alleged “must be enough to raise a right to relief above the speculative level.” Twombly, 550 U.S. at 555. This standard “demands more than an unadorned, the-defendant-unlawfully- harmed-me accusation.” Iqbal, 556 U.S. at 678. Determining whether a complaint states a plausible claim for relief is a context-specific task that requires the reviewing court to draw upon judicial experience and common sense. Id. at 679. The court must assume the veracity of well- pleaded facts, but need not accept as true “[t]hreadbare recitals of the elements of a cause of action, supported by mere conclusory statements.” Id. at 678 (citing Twombly, 550 U.S. at 555).

This Court must liberally construe complaints filed by laypeople. Estelle v. Gamble, 429 U.S. 97, 106 (1976). This means that “if the essence of an allegation is discernible,” the court should “construe the complaint in a way that permits the layperson’s claim to be considered within the proper legal framework.” Solomon v. Petray, 795 F.3d 777, 787 (8th Cir. 2015) (quoting Stone v. Harry, 364 F.3d 912, 914 (8th Cir. 2004)). However, even pro se complaints must allege facts which, if true, state a claim for relief as a matter of law. Martin v. Aubuchon, 623 F.2d 1282, 1286 (8th Cir. 1980). Federal courts are not required to assume facts that are not alleged, Stone, 364 F.3d at 914–15, nor are they required to interpret procedural rules so as to excuse mistakes by those who proceed without counsel. See McNeil v. United States, 508 U.S. 106, 113 (1993). The Complaint

Plaintiff filed the complaint pursuant to 42 U.S.C. § 1983 against the Missouri Department of Corrections (“MDOC”) and the Moberly Correctional Center (“MCC”). He claims he suffered injury to his right knee when he fell from his bunk. He can be understood to allege the fall occurred because the defendants’ employee(s) failed to properly maintain and/or repair the bunk. Plaintiff alleges he received medical treatment after the fall, but he also appears to indicate he was not provided certain treatment and/or medically-necessary items. He claims that a cell inspection was not performed, necessary repairs were not done, and he was not given a room safety inspection checklist. He seeks monetary relief. After filing the complaint, plaintiff submitted two filings in an attempt to supplement it. The filings contain a variety of documents, including grievance materials plaintiff submitted concerning the alleged failure to maintain the bunk, materials concerning his efforts to secure representation by counsel, and medical lay-in forms. Plaintiff seeks monetary relief. Discussion

Plaintiff filed the complaint pursuant to § 1983 to seek relief from the MDOC and the MCC. The MDOC is a state agency, see Walker v. Missouri Dept. of Corrections, 213 F.3d 1035, 1036 (8th Cir. 2000), and the MCC is a MDOC facility. Therefore, this suit is effectively a suit against the State of Missouri. “Section 1983 provides for an action against a ‘person’ for a violation, under color of law, of another's civil rights.” McLean v. Gordon, 548 F.3d 613, 618 (8th Cir. 2008). However, the State of Missouri and its agencies are not “persons” within the meaning of § 1983. See Will v. Michigan Dept. of State Police, 491 U.S. 58, 71 (1989), Alsbrook v. City of Maumelle, 184 F.3d 999, 1010 (8th Cir. 1999). Additionally, the “Eleventh Amendment protects States and their arms and instrumentalities from suit in federal court.” Webb v. City of Maplewood, 889 F.3d 483, 485 (8th Cir. 2018). See Egerdahl v. Hibbing Cmty. Coll., 72 F.3d 615, 618-19 (8th

Cir. 1995) (“Generally, in the absence of consent a suit in which the State or one of its agencies or departments is named as the defendant is proscribed by the Eleventh Amendment.”). Plaintiff does not allege, nor is it apparent, that an exception to Eleventh Amendment immunity applies in this case. See Barnes v. State of Missouri, 960 F.2d 63, 64 (8th Cir. 1992). Therefore, this action is subject to dismissal pursuant to 28 U.S.C. § 1915A. However, the Court will not dismiss this action at this time, and will instead give plaintiff the opportunity to file an amended complaint. Plaintiff is advised that the amended complaint will replace the original. See In re Wireless Telephone Federal Cost Recovery Fees Litigation, 396 F.3d 922, 928 (8th Cir. 2005) (“It is well- established that an amended complaint supersedes an original complaint and renders the original complaint without legal effect”).

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Related

Estelle v. Gamble
429 U.S. 97 (Supreme Court, 1976)
Neitzke v. Williams
490 U.S. 319 (Supreme Court, 1989)
Will v. Michigan Department of State Police
491 U.S. 58 (Supreme Court, 1989)
McNeil v. United States
508 U.S. 106 (Supreme Court, 1993)
Bell Atlantic Corp. v. Twombly
550 U.S. 544 (Supreme Court, 2007)
Ashcroft v. Iqbal
556 U.S. 662 (Supreme Court, 2009)
Richard R. Barnes v. State of Missouri
960 F.2d 63 (Eighth Circuit, 1992)
McLean v. Gordon
548 F.3d 613 (Eighth Circuit, 2008)
Popoalii v. Correctional Medical Services
512 F.3d 488 (Eighth Circuit, 2008)
Samvel Topchian v. JPMorgan Chase Bank, N.A.
760 F.3d 843 (Eighth Circuit, 2014)
James Solomon v. Deputy U.S. Marshal Thomas
795 F.3d 777 (Eighth Circuit, 2015)
Mark Neubauer v. FedEx Corporation
849 F.3d 400 (Eighth Circuit, 2017)
Cecelia Webb v. City of Maplewood
889 F.3d 483 (Eighth Circuit, 2018)
Patric Patterson v. Kennie Bolden
902 F.3d 845 (Eighth Circuit, 2018)
Martin v. Aubuchon
623 F.2d 1282 (Eighth Circuit, 1980)

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Brown v. Missouri Department of Corrections, Counsel Stack Legal Research, https://law.counselstack.com/opinion/brown-v-missouri-department-of-corrections-moed-2022.