Charles E. Birtch v. Rowan County et al.

CourtDistrict Court, M.D. North Carolina
DecidedFebruary 24, 2026
Docket1:26-cv-00153
StatusUnknown

This text of Charles E. Birtch v. Rowan County et al. (Charles E. Birtch v. Rowan County et al.) is published on Counsel Stack Legal Research, covering District Court, M.D. North Carolina primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Charles E. Birtch v. Rowan County et al., (M.D.N.C. 2026).

Opinion

IN THE UNITED STATES DISTRICT COURT FOR THE MIDDLE DISTRICT OF NORTH CAROLINA

CHARLES E. BIRTCH, ) ) Plaintiff, ) ) v. ) 1:26CV153 ) ROWAN COUNTY et al., ) ) Defendant(s). ) ORDER AND RECOMMENDATION OF UNITED STATES MAGISTRATE JUDGE Plaintiff, a prisoner of the State of North Carolina who was previously detained in the Rowan County Detention Center, submitted a pro se complaint under 42 U.S.C. § 1983 and requests permission to proceed in forma pauperis pursuant to 28 U.S.C. § l915(a). The Complaint names Rowan County, the Rowan County Detention Center, the Rowan County Sheriff’s Office, Unknown Correctional Officers, Unknown Medical Staff, and Unknown Administrators as Defendants. The Complaint alleges that Defendants did not implement appropriate policies and procedures to ensure the safety of inmates in the Detention Center and did not properly supervise inmates. It claims that this led to an assault on Plaintiff by other inmates after Plaintiff would not provide an unidentified inmate with his telephone PIN. The assault allegedly injured Plaintiff’s right eye on September 20, 2022. The Complaint also alleges that Plaintiff had two eye surgeries for the injuries and had another scheduled for December of 2022, but that it never occurred because Rowan County cancelled the surgery. Plaintiff raises claims under § 1983 and under state law based on personal injury claims for negligence and gross negligence. He seeks damages and coverage of the cost of future surgeries as relief.

Because Plaintiff is “a prisoner seek[ing] redress from a governmental entity or officer or employee of a governmental entity,” this Court has an obligation to “review” this Complaint. 28 U.S.C. § 1915A(a). “On review, the court shall . . . dismiss the complaint, or any portion of the complaint, if [it] – (1) is 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.” 28 U.S.C. § 1915A(b). As to the first basis for dismissal, the United States Supreme Court has explained that “a complaint, containing as it does both factual allegations and legal conclusions, is frivolous where it lacks an arguable basis either in law or in fact.” Neitzke v. Williams, 490 U.S. 319,

325 (1989). “The word ‘frivolous’ is inherently elastic and not susceptible to categorical definition. . . . The term’s capaciousness directs lower courts to conduct a flexible analysis, in light of the totality of the circumstances, of all factors bearing upon the frivolity of a claim.” Nagy v. Federal Med. Ctr. Butner, 376 F.3d 252, 256-57 (4th Cir. 2004) (some internal quotation marks omitted). As part of this review, the Court may anticipate

affirmative defenses that clearly appear on the face of the complaint. Nasim v. Warden, Md. House of Corr., 64 F.3d 951, 954 (4th Cir. 1995) (en banc); Todd v. Baskerville, 712 F.2d 70, 74 (4th Cir. 1983).

-2- The Supreme Court further has identified factually frivolous complaints as ones involving “allegations that are fanciful, fantastic, and delusional. As those words suggest, a finding of factual frivolousness is appropriate when the facts alleged rise to the level of the

irrational or the wholly incredible, whether or not there are judicially noticeable facts available to contradict them.” Denton v. Hernandez, 504 U.S. 25, 32-33 (1992) (internal citations and quotation marks omitted). In making such findings, this Court may “apply common sense.” Nasim, 64 F.3d at 954.

Alternatively, a plaintiff “fails to state a claim upon which relief may be granted,” 28 U.S.C. § 1915A(b)(1), when the complaint does not “contain sufficient factual matter, accepted as true, to ‘state a claim to relief that is plausible on its face.’” Ashcroft v. Iqbal, 556 U.S. 662, 678 (2009) (emphasis added) (internal citations omitted) (quoting Bell Atl. Corp. v. Twombly, 550 U.S. 544, 570 (2007)). “Where a complaint pleads facts that are

‘merely consistent with’ a defendant’s liability, it ‘stops short of the line between possibility and plausibility of “entitlement to relief.”’” Id. (quoting Twombly, 550 U.S. at 557). This standard “demands more than an unadorned, the-defendant-unlawfully-harmed-me accusation.” Id. In other words, “the tenet that a court must accept as true all of the allegations contained in a complaint is inapplicable to legal conclusions. Threadbare recitals

of the elements of a cause of action, supported by mere conclusory statements, do not suffice.” Id.1

1Although the Supreme Court has reiterated that “[a] document filed pro se is to be liberally construed and a pro se complaint, however inartfully pleaded, must be held to less stringent standards than formal pleadings drafted by (continued...) -3- For the reasons that follow, the Complaint should be dismissed pursuant to 28 U.S.C. § 1915A(b) because it is frivolous and because it fails to state a claim on which relief may be granted.

As an initial matter, Plaintiff’s Complaint does not name or identify proper Defendants and/or fails to allege any basis for liability for the Defendants named. One of the Defendants listed in the Complaint is the Rowan County Detention Center. Claims under § 1983 can only be brought against “persons” who violate a plaintiff’s rights. However, the

Detention Center is a building, not a person, and therefore not a proper Defendant under § 1983. The Complaint also names Rowan County and the Rowan County Sheriff’s Office as Defendants on the basis that they control the Detention Center and employ, train, and supervise the persons who work there. Under North Carolina law, the Sheriff of Rowan County, not the County itself, controls the operations of the Detention Center and possesses

final policymaking authority. See Cobbs ex rel. Cobbs v. County of Guilford, No. 1:10CV806, 2012 WL 3113141, at *2 (M.D.N.C. July 31, 2012) (unpublished), rec. adopted as modified, 2012 WL 4508106, (M.D.N.C. Sept. 28, 2012) (unpublished). Therefore, Rowan County is not a proper Defendant and Plaintiff would likely need to substitute the

1(...continued) lawyers,” Erickson v. Pardus, 551 U.S. 89, 94 (2007) (internal citations and quotation marks omitted), the United States Court of Appeals for the Fourth Circuit has “not read Erickson to undermine Twombly’s requirement that a pleading contain more than labels and conclusions,” Giarratano v. Johnson, 521 F.3d 298, 304 n.5 (4th Cir. 2008) (internal quotation marks omitted) (applying Twombly standard in dismissing pro se complaint); accord Atherton v. District of Columbia Off. of Mayor, 567 F.3d 672, 681-82 (D.C. Cir. 2009) (“A pro se complaint . . .

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Related

Wilson v. Garcia
471 U.S. 261 (Supreme Court, 1985)
Neitzke v. Williams
490 U.S. 319 (Supreme Court, 1989)
Denton v. Hernandez
504 U.S. 25 (Supreme Court, 1992)
Erickson v. Pardus
551 U.S. 89 (Supreme Court, 2007)
Bell Atlantic Corp. v. Twombly
550 U.S. 544 (Supreme Court, 2007)
Ashcroft v. Iqbal
556 U.S. 662 (Supreme Court, 2009)
Paul Nagy v. Fmc Butner
376 F.3d 252 (Fourth Circuit, 2004)
Giarratano v. Johnson
521 F.3d 298 (Fourth Circuit, 2008)
Farmer v. Brennan
511 U.S. 825 (Supreme Court, 1994)
Todd v. Baskerville
712 F.2d 70 (Fourth Circuit, 1983)

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Bluebook (online)
Charles E. Birtch v. Rowan County et al., Counsel Stack Legal Research, https://law.counselstack.com/opinion/charles-e-birtch-v-rowan-county-et-al-ncmd-2026.