Bryant v. Effingham County Jail

CourtDistrict Court, S.D. Georgia
DecidedMarch 1, 2023
Docket4:23-cv-00024
StatusUnknown

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

Bluebook
Bryant v. Effingham County Jail, (S.D. Ga. 2023).

Opinion

UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF GEORGIA SAVANNAH DIVISION

BENITO DAVID BRYANT, ) ) Plaintiff, ) ) v. ) CV423-024 ) EFRFINGHAM COUNTY JAIL, ) and EFFINGHAM COUNTY ) SHERIFF’S DEPARTMENT, ) ) Defendant. )

ORDER Pro se plaintiff Benito David Bryant filed this 42 U.S.C. § 1983 case, seeking “release for eye surgery.” See doc. 1 at 6. The Court granted him leave to proceed in forma pauperis, doc. 4, and he returned the required forms, docs. 6 & 7. The Court must, therefore, screen his Complaint, pursuant to 28 U.S.C. § 1915A. Although his Complaint fails to state a claim upon which relief may be granted, see 28 U.S.C. § 1915A(b)(1), he will have an opportunity to amend it. Because the Court applies Federal Rule of Civil Procedure 12(b)(6) standards in screening a complaint pursuant to § 1915A, Leal v. Ga. Dep’t of Corr., 254 F.3d 1276, 1278-79 (11th Cir. 2001), allegations in the Complaint are taken as true and construed in the light most favorable to the plaintiff, Bumpus v. Watts, 448 F. App’x 3, 4 n.1 (11th Cir. 2011). The

facts that Bryant alleges are straightforward, if terse. See doc. 1 at 5. He alleges that he was diagnosed with an unspecified “eye condition” by the

Department of Veterans’ Affairs (the “VA”). Id. He complained about the condition, or perhaps side effects of surgery he received from the VA, to unidentified individuals “for six months,” and “experienced . . . eye pain

with no relief.” Id. at 3, 5. He has also listed a series of dates and numbers, perhaps administrative grievance numbers. Id. at 5. The only defendants he identifies are the Effingham County Sheriff’s Department

and Effingham County Jail. See id. at 1, 4. First, Bryant has not named a proper defendant. Jails and prisons are not entities subject to suit under § 1983. See, e.g., Meyers v. Chatham

Cnty. Det. Ctr., 2022 WL 1215640, at *1 (S.D. Ga. Apr. 25, 2022) (“[T]he Chatham County Detention Center is not an entity subject to suit.”). Similarly, sheriffs’ departments are not entities subject to suit. See, e.g.,

Dempsey v. Elmore, 2008 WL 4491475, at *5 (S.D. Ga. Oct. 3, 2008) (holding “Plaintiff cannot state a valid claim against the Chatham County Sheriff’s Department because it is not subject to suit under 42 U.S.C. § 1983.”). Accordingly, to the extent that Bryant names either the Effingham County Jail or the Effingham County Sheriff’s Department,

those defendants are DISMISSED. Bryant’s allegations implicate, even if they do not state, a possible

inadequate-medical-care claim. Prison officials’ deliberate indifference to “an inmate’s serious medical needs violates the inmate’s right to be free from cruel and unusual punishment.” Waldrop v. Evans, 871 F.2d

1030, 1033 (11th Cir. 1989) (citing Estelle v. Gamble, 429 U.S. 97, 104-05 (1976)); see Farmer v. Brennan, 511 U.S. 825, 832-33 (1994) (although prison conditions may be restrictive and harsh, prison officials must

provide, inter alia, necessary medical care). This requires that (1) the prisoner suffered a sufficiently serious medical need; (2) to which the defendants were deliberately indifferent; (3) resulting in an injury.

Goebert v. Lee Cty., 510 F.3d 1312, 1326 (11th Cir. 2007). Whether a serious medical need existed is an objective standard. Milton v. Turner, 445 F. App’x 159, 161-62 (11th Cir. 2011). To allege deliberate

indifference, a plaintiff must show “(1) subjective knowledge of a risk of serious harm; (2) disregard of that risk; (3) by conduct that is more than [gross] negligence.” Youmans v. Gagnon, 626 F.3d 557, 564 (11th Cir. 2010) (internal quotations and citation omitted). Each defendant is “judged separately and on the basis of what that person knows.” Burnette

v. Taylor, 533 F.3d 1325, 1331 (11th Cir. 2008). A prisoner’s mere disagreement with the type of medical treatment he receives is

insufficient to allege deliberate indifference. See, e.g., Hamm v. DeKalb Cnty., 774 F.2d 1567, 1575 (11th Cir. 1985). Even if the treatment an inmate received was negligent, that’s not enough to support a § 1983

claim. See, e.g. Harris v. Thigpen, 941 F.2d 1495, 1505 (11th Cir. 1991) (citing Estelle, 429 U.S. at 106) (“Mere incidents of [medical] negligence or malpractice do not rise to the level of constitutional violations.”).

Bryant’s allegation of an unspecified “eye condition” is too vague to allege a serious medical need and his failure to identify any individual involved is insufficient to allege deliberate indifference.

Finally, his request for “release for eye surgery” is not clearly cognizable in a § 1983 case. “[A] prisoner in state custody cannot use a § 1983 action to challenge the fact or duration of his confinement. . . . He

must seek federal habeas corpus relief (or appropriate state relief) instead.” Wilkinson v. Dotson, 544 U.S. 74, 78 (2005) (quotes and cites omitted); Heck v. Humphrey, 512 U.S. 477, 481 (1994) (“[H]abeas corpus is the exclusive remedy for a state prisoner who challenges the fact or duration of his confinement and seeks immediate or speedier release,

even though such a claim may come within the literal terms of § 1983.”). And before he can bring a federal habeas action, he must first exhaust

his available state remedies through either a direct appeal or another petition for state collateral relief. Wilkinson, 544 U.S. at 79 (federal “habeas corpus actions require a petitioner fully to exhaust state

remedies, which § 1983 does not”); 28 U.S.C. §§ 2254(b), (c). Although Bryant requests “release,” it is not entirely clear from his Complaint that he does not, in fact, seek injunctive relief requiring some treatment,

rather than “release.” His amendment, discussed below, must clarify the nature of the relief requested. In summary, Bryant has failed to state any claim arising from his

treatment at Effingham County Jail. Despite his Complaint’s failure to state a viable claim, “when a more carefully drafted complaint might state a claim, a district court should give a pro se plaintiff at least one

chance to amend the complaint before the court dismisses the action.” Jenkins v. Walker, 620 F. App’x 709, 711 (11th Cir. 2015). Accordingly, Bryant is DIRECTED to submit an Amended Complaint no later than March 24, 2023. To facilitate his preparation of the Amended Complaint, the Clerk is DIRECTED to send him a blank Form Pro Se 14 (Complaint

for Violation of Civil Rights (Prisoner)). Bryant is advised that his amended complaint will supersede the current operative complaint and

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Related

Goebert v. Lee County
510 F.3d 1312 (Eleventh Circuit, 2007)
Burnette v. Taylor
533 F.3d 1325 (Eleventh Circuit, 2008)
Estelle v. Gamble
429 U.S. 97 (Supreme Court, 1976)
Heck v. Humphrey
512 U.S. 477 (Supreme Court, 1994)
Wilkinson v. Dotson
544 U.S. 74 (Supreme Court, 2005)
John Eugene Youmans v. M. J. Oschner
626 F.3d 557 (Eleventh Circuit, 2010)
Milton v. Turner
445 F. App'x 159 (Eleventh Circuit, 2011)
George Hamm v. Dekalb County, and Pat Jarvis, Sheriff
774 F.2d 1567 (Eleventh Circuit, 1985)
Sirica Bumpus v. Harrell Watts, Mr Peterson
448 F. App'x 3 (Eleventh Circuit, 2011)
Farmer v. Brennan
511 U.S. 825 (Supreme Court, 1994)
Adrian Jenkins v. Susan M. Walker
620 F. App'x 709 (Eleventh Circuit, 2015)
Harris v. Thigpen
941 F.2d 1495 (Eleventh Circuit, 1991)

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Bryant v. Effingham County Jail, Counsel Stack Legal Research, https://law.counselstack.com/opinion/bryant-v-effingham-county-jail-gasd-2023.