Christopher L. Childs v. Rappahannock Regional Jail

CourtDistrict Court, E.D. Virginia
DecidedMay 6, 2026
Docket1:25-cv-01737
StatusUnknown

This text of Christopher L. Childs v. Rappahannock Regional Jail (Christopher L. Childs v. Rappahannock Regional Jail) is published on Counsel Stack Legal Research, covering District Court, E.D. Virginia primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Christopher L. Childs v. Rappahannock Regional Jail, (E.D. Va. 2026).

Opinion

IN THE UNITED STATES DISTRICT COURT FOR THE EASTERN DISTRICT OF VIRGINIA Alexandria Division Christopher L. Childs, ) Plaintiff, ) ) Vv. ) No. 1:25ev1737 (RDA/IDD) ) Rappahannock Regional Jail, ) Defendant. ) MEMORANDUM OPINION AND ORDER This matter is before the Court to screen Virginia inmate Christopher L. Childs’ pro se complaint, filed pursuant to 42 U.S.C. § 1983 alleging that his Eighth Amendment rights were violated because he did not receive adequate medical care while detained at the Rappahannock Regional Jail in Stafford, Virginia. Dkt. No. 1. The Court must screen a prisoner’s complaint to determine whether it is frivolous, malicious, or fails to state any claims upon which relief may be granted. See 28 U.S.C. § 1915A.! Il. Standard of Review In reviewing a complaint pursuant to § 1915A, a district court thus applies the same standard as a Rule 12(b)(6) motion. To survive such a motion, “a complaint must 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) (quoting Bell Atlantic Corp. v. Twombly, 550 U.S. 544, 570 (2007)). A claim is

1 Section 1915A provides: (a) Screening.—The 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. (b) Grounds for dismissal.—On review, the court shall identify cognizable claims or dismiss the complaint, or any portion of the complaint, if the complaint— (1) is frivolous, malicious, or fails to state a claim upon which relief can be granted; or (2) seeks monetary relief from a defendant who is immune from such relief.

facially plausible if “the factual content of a complaint allows the court to draw the reasonable inference that the defendant is liable for the misconduct alleged.” Nemet Chevrolet, Lid. v. Consumeraffairs.com, Inc., 591 F.3d 250, 256 (4th Cir. 2009) (citation omitted). A complaint must therefore allege facts in support of each element of each claim the plaintiff raises; “threadbare recitals of the elements of a cause of action, supported by mere conclusory statements,” are insufficient. /gbal, 556 U.S. at 678. “[A] plaintiffs obligation to provide the grounds of his entitlement to relief requires more than labels and conclusions, and a formulaic recitation of the elements of a cause of action will not do.” /d. (internal quotation marks and citations omitted). While a court must construe a pro se complaint liberally, a court “is not bound by the complaint’s legal conclusions,” conclusory allegations, or unwarranted inferences. Robinson v. Am. Honda Motor Co., 551 F.3d 218, 222 (4th Cir. 2009). In order to screen a complaint, it must present a coherent, comprehensible, and intelligible document. “[A] plaintiffs obligation to provide the grounds of his entitlement to relief requires more than labels and conclusions, and a formulaic recitation of the elements of a cause of action will not do.” Twombly, 550 U.S. at 555. A complaint must “give the defendant fair notice of what the plaintiff's claim is and the grounds upon which it rests.” Conley v. Gibson, 355 U.S. 41, 47 (1957); Jennings v. Emry, 910 F.2d 1434, 1436 (7th Cir. 1990) (a pleading must be presented “with clarity sufficient to avoid requiring a district court or opposing party to forever sift through its pages in search” of the pleader’s claims “without untoward effort”). “Threadbare recitals of the elements of a cause of action, supported by mere conclusory statements, do not suffice.” Iqbal, 556 U.S. at 678 (citing Twombly, 550 USS. at 555). Plaintiff’ s complaint has several deficiencies. First, the only named defendant is Rappahannock Regional Jail, an adult correctional facility located in Stafford, Virginia. However, “[b]ecause a jail is not a legal entity, it is not a ‘person’ subject to suit under § 1983.” Dales v. Haysi Reg’! Jail, No. 7:16cv386, 2016 WL 7168278, at *1 (W.D. Va. Dec. 8, 2016), *1 (W.D. Va. Dec. 8, 2016) (citing McCoy v. Chesapeake Corr. Ctr., 788 F. Supp. 890, 894 (E.D. Va. 1992), aff'd, 9 F.3d 1544 (4th Cir.

1993) (table case)); see Painter v. Blue Ridge Reg’l Jail Auth., No. 6:17cev34, 2017 WL 3725993, at *5 (W.D. Va. Aug. 29, 2017) (holding that a regional jail “is not subject to suit under § 1983 because it is an arm of the Commonwealth of Virginia” and collecting cases). See Preval v. Reno, 203 F.3d 821, at *1 [published in full-text format at 2000 WL 20591, at *1 (4th Cir. January 13, 2000) (per curiam) (unpublished).? Because Rappahannock Regional Jail is not a person under § 1983 it must be dismissed as a defendant, with prejudice. Furthermore, to state a cause of action under § 1983, a plaintiff must allege facts indicating that he was deprived of rights guaranteed by the Constitution or laws of the United States and that the alleged deprivation resulted from conduct committed by a person acting under color of state law. See West v. Atkins, 487 U.S. 42, 48 (1988). The complaint presents a conclusory Eighth Amendment claim for inadequate medical care but does not name a serious medical need, he only states he requested to see “mental health” about his lack of medication. Estelle v. Gamble, 429 U.S. 97, 105 (1976); Staples v. Va. Dep’t of Corr., 904 F. Supp. 487, 492 (E.D. Va. 1995). Thus, Plaintiff must allege two distinct elements to state a claim upon which relief can be granted. First, he must allege a sufficiently serious medical need. A serious medical need is one that poses a substantial risk of serious injury to an inmate’s health and safety. Young v. City of Mt. Ranier, 238 F.3d 567, 576 (4th Cir. 2001). Second, he must allege deliberate indifference to that serious medical need. Under this second prong, an assertion of mere negligence or even malpractice is not enough to state an Eighth Amendment violation; instead, plaintiff must allege deliberate indifference “by either actual intent or reckless disregard.” Estelle, 429 U.S. at 106; Miltier, 896 F.2d at 851. A prisoner’s disagreement with medical personnel over the course of his treatment does not make out a cause of action. Wright v. Collins, 766 F.2d 841, 849 (4th Cir. 1985); Harris v. Murray, 761 F. Supp. 409, 414 (E.D. Va. 1990). Here, Plaintiff alleges that vague

2 The Fourth Circuit affirmed the district court opinion in Preval v. Reno, 57 F.Supp.2d 307 (E.D.Va.1999), which held that “the Piedmont Regional Jail is not a ‘person’ .. . under 42 U.S.C. § 1983.” /d. at 310 (citing Will v. Michigan Department of State Police, 491 U.S. 58 (1989); McCoy v. Chesapeake Correctional Center, 788 F. Supp. 890 (1992)).

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Related

Conley v. Gibson
355 U.S. 41 (Supreme Court, 1957)
Estelle v. Gamble
429 U.S. 97 (Supreme Court, 1976)
West v. Atkins
487 U.S. 42 (Supreme Court, 1988)
Will v. Michigan Department of State Police
491 U.S. 58 (Supreme Court, 1989)
Bell Atlantic Corp. v. Twombly
550 U.S. 544 (Supreme Court, 2007)
Ashcroft v. Iqbal
556 U.S. 662 (Supreme Court, 2009)
Rhodes v. Robinson
621 F.3d 1002 (Ninth Circuit, 2010)
Jennings v. Emry
910 F.2d 1434 (Seventh Circuit, 1990)
Robinson v. American Honda Motor Co., Inc.
551 F.3d 218 (Fourth Circuit, 2009)
Nemet Chevrolet, Ltd. v. Consumeraffairs. Com, Inc.
591 F.3d 250 (Fourth Circuit, 2009)
McCoy v. Chesapeake Correctional Center
788 F. Supp. 890 (E.D. Virginia, 1992)
Harris v. Murray
761 F. Supp. 409 (E.D. Virginia, 1990)
Staples v. Virginia Department of Corrections
904 F. Supp. 487 (E.D. Virginia, 1995)
Preval v. Reno
57 F. Supp. 2d 307 (E.D. Virginia, 1999)

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Bluebook (online)
Christopher L. Childs v. Rappahannock Regional Jail, Counsel Stack Legal Research, https://law.counselstack.com/opinion/christopher-l-childs-v-rappahannock-regional-jail-vaed-2026.