Burns v. Chatham County Detention Center

CourtDistrict Court, S.D. Georgia
DecidedJuly 17, 2024
Docket4:21-cv-00113
StatusUnknown

This text of Burns v. Chatham County Detention Center (Burns v. Chatham County Detention Center) 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
Burns v. Chatham County Detention Center, (S.D. Ga. 2024).

Opinion

UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF GEORGIA SAVANNAH DIVISION LARRY JEROME BURNS, JR., ) ) Plaintiff, ) ) v. ) CV421-113 ) CHATHAM CNTY. DET. CTR., ) et. al., ) ) Defendants. ) ORDER Proceeding pro se and in forma pauperis, Plaintiff Larry Burns, Jr. filed this 42 U.S.C. § 1983 action against Chatham County Detention Center, “Capt Irving,” Trevor King, “Miss C. Lewis,” “Miss Scott,” “Miss Taylor,” “Miss Gordo,” and “Mr. B. Kephart.” Doc. 1. The Court granted Plaintiff’s request to pursue his case in forma pauperis (IFP), doc. 4, but Plaintiff never returned the necessary forms. He did, however, draft a letter to the Court claiming that “Miss Gordon,” who is a Defendant in the case, was “being arbitrary to the facts,” and “trying to make [him] miss the deadline [to return the form] deliberately.” Doc. 8 at 1. In

another letter, Plaintiff complains that the prison never returned his prisoner trust fund account statement or his consent to collection of fees from trust fund account forms. Doc. 9. He also informed the Court that

he was released from prison. Id. Nevertheless, Burns’ Complaint must be screened by the Court pursuant to the Prison Litigation Reform Act (PLRA).

I. Legal Standard Under the PLRA, a federal court is required to conduct an initial screening of all prisoner complaints. 28 U.S.C. § 1915A(b). In conducting

the review, the Court must identify all “cognizable claims” and dismiss the complaint, or any portion thereof, that is “(1) frivolous, malicious, or fails to state a claim upon which relief may be granted; or (2) seeks

monetary relief from a defendant who is immune from such relief.” Id. The complaints of unrepresented parties are held to a less stringent standard than those drafted by an attorney and are afforded a liberal

construction, Estelle v. Gamble, 429 U.S. 97, 106 (1976) (“a pro se complaint, however inartfully pleaded, must be held to less stringent standards than formal pleadings drafted by lawyers (internal quotations

omitted)); however, they must still comply with procedural requirements, McNeil v. United States, 508 U.S. 106, 113 (1993). To state a claim, a pleading must contain a “short and plain

statement of the claim showing that the pleader is entitled to relief[.]” Fed. R. Civ. P. 8(a)(2). “A plaintiff . . . must plead facts sufficient to show that [his] claim has substantive plausibility” and to inform the defendant

of “the factual basis” for the complaint. Johnson v. City of Shelby, Miss., 574 U.S. 10, 12 (2014). The complaint must contain “more than labels and conclusions, and a formulaic recitation of the elements of a cause of

action will not” suffice. Bell Atl. Corp. v. Twombly, 550 U.S. 544, 555 (2007). In its screening, the Court also applies the Federal Rule of Civil Procedure 12(b)(6), Leal v. Ga. Dep’t of Corr., 254 F.3d 1276, 1278–79

(11th Cir. 2001), accepting all allegations as true and construing them in the light most favorable to the plaintiff. See Bumpus v. Watts, 448 F. App’x 3, 4 n.1 (11th Cir. 2011).

II. Analysis of Allegations Plaintiff was incarcerated in July 2020 at Chatham County Detention Center. While the incidents giving rise to his complaint

occurred after his placement there, the Chatham County Detention Center must be DISMISSED because it is not an entity subject to suit under 42 U.S.C. § 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.”). As to his other claims, the Court finds as follows. A. Denial of Medical Care

Plaintiff’s claims that he was forced by the prison doctor, whom he does not name as a Defendant, to return to general population before his arm was completely healed from an injury he sustained during an attack

by other prisoners. Doc. 1 at 7. He claims that two inmates saw that he was weakened and attacked him during the healing process, causing further damage. Id. He also claims that he has been denied “chronic

care” medication for pain. Id. at 10. To offend the Eighth Amendment, a government official must display “deliberate indifference to the serious medical needs of prisoners

. . . .” Estelle, 429 U.S. at 104. 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). However, whether defendants were deliberately indifferent is subjective and 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). To show deliberate indifference, Plaintiff here must show that

Defendants had a (1) subjective knowledge of a risk of serious harm; (2) disregard of that risk; (3) by conduct which constitutes “subjective recklessness as used in the criminal law.” Wade v. McDade, ___ F.4th

___, 2024 WL 3354963, *2 (11th Cir. July 10, 2024) (articulating deliberate indifference as “subjective recklessness” as that term is used in criminal law);1 see also McElligott v. Foley, 182 F.3d 1248, 1255 (11th

Cir. 1999). To meet his burden under the third prong, Plaintiff must show that the Defendant was “subjectively aware that his own conduct put the plaintiff at substantial risk of serious harm—with the caveat

that, in any event, a defendant who ‘respond[s] reasonably’ to a risk, even a known risk, ‘cannot be found liable’ under the Eighth Amendment. Wade, 2024 WL 3354963 at *2 (citations omitted).

1 But see id. at *10 (Jordan, J. concurring and instructing courts to “look carefully at prior Eleventh Circuit cases to see if they are consistent with the subjective component of deliberate indifference set out in Farmer” to confirm they may continue being cited as binding precedent instead of abrogating all deliberate indifference cases prior to Wade.) The Court assumes, without deciding, that Plaintiff suffered a

sufficiently serious medical need, as he claims his arm “came out of the socket.” Doc. 1 at 5. However, he fails to allege that any Defendant was deliberately indifferent to that need. He merely complains that the arm

was not completely healed and that other inmates took advantage of his weakness. Even assuming that the decision to return him to general population was hasty, such a decision constitutes negligence at best. “A

complaint that a physician has been negligent in diagnosing or treating a medical condition does not state a valid claim of medical mistreatment under the Eighth Amendment.” McElligott, 182 F.3d at 1254 (quoting

Estelle, 429 U.S. at 106). “Medical malpractice does not become a constitutional violation merely because the victim is a prisoner.” Id.; see also Brown v.

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Burns v. Chatham County Detention Center, Counsel Stack Legal Research, https://law.counselstack.com/opinion/burns-v-chatham-county-detention-center-gasd-2024.