Coleman v. Onuoha

District Court, D. South Carolina·Decided September 9, 2025·No. 9:24-cv-03158·Unknown

Opinion

IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF SOUTH CAROLINA

Stye Lamar Coleman, ) C.A. No. 9:24-cv-03158-TMC-MHC ) Plaintiff, ) ) v. ) REPORT AND RECOMMENDATION ) Dr. Onuoha and Ms. Sinclair, ) ) Defendants. ) ____________________________________)

This action has been filed by Plaintiff, who is proceeding pro se and in forma pauperis, alleging constitutional violations under 42 U.S.C. § 1983. ECF No. 21. Before the Court is Plaintiff’s Motion for Preliminary Injunction. ECF No. 44. Defendants filed a Response in Opposition. ECF No. 50. The matter is ripe for review.1 BACKGROUND Plaintiff is a federal inmate at Federal Correctional Institution (“FCI”) Beckley. ECF No. 21 at 2. In his Amended Complaint, Plaintiff alleges that while housed at FCI Bennettsville, he suffered injuries to his head and neck while using equipment in the recreation yard because the equipment was not bolted down. Id. at 5. Plaintiff alleges he fell headfirst and was bleeding from the head until medical arrived, when he was provided aspirin and bandages. Id. at 5–6. No concussion protocols or x-rays were performed. Id. at 6. Plaintiff brings claims for violations of his Eighth Amendment rights and for negligence. Id. at 4. DISCUSSION Plaintiff has moved for a preliminary injunction, asking that this Court order the Federal

1 Pursuant to the provisions of Title 28, United States Code, Section 636(b)(1)(B), and Local Civil Rule 73.02(B)(2), DSC, the undersigned is authorized to review petitions for injunctive relief and submit findings and recommendations to the District Judge. Bureau of Prisons to cease the withholding of medical care. ECF No. 44 at 1. Plaintiff states he has suffered serious injuries to his back, as stated in his Amended Complaint, and the injuries will lead to irreparable damage if not properly treated. Id. Plaintiff notes he has not been seen by an outside doctor since his injury, and this Motion for Preliminary Injunction is his only other

available avenue for relief. Id. A preliminary injunction is “an extraordinary remedy involving the exercise of a very far- reaching power, which is to be applied only in the limited circumstances which clearly demand it.” Centro Tepeyac v. Montgomery Cnty., 722 F.3d 184, 188 (4th Cir. 2013) (internal quotation marks omitted) (quoting Direx Israel, Ltd. v. Breakthrough Med. Corp., 952 F.2d 802, 811 (4th Cir. 1991)). The decision whether to grant a preliminary injunction is committed to the equitable discretion of the district court. See Salazar v. Buono, 559 U.S. 700, 714 (2010); Christopher Phelps & Assocs., LLC v. Galloway, 492 F.3d 532, 543 (4th Cir. 2007). As an initial matter, Plaintiff is not entitled to the injunctive relief he seeks because the wrong or wrongs that Plaintiff’s requested injunctive relief would protect against fall outside the

scope of the Amended Complaint and Defendants’ control. Plaintiff seeks an order demanding actions by the Federal Bureau of Prisons. ECF No. 44 at 1. However, Plaintiff’s Amended Complaint brings claims against two individual Defendants based on their actions while employed at FCI Bennettsville. See ECF No. 21 at 2–6. Generally, “a court may not enter an injunction against a person who has not been made a party to the case before it.” Pew v. Wetzel, No. 3:12- CV-1984, 2015 WL 10474859, at *4 (M.D. Pa. Oct. 30, 2015) (quoting Additive Controls & Measurement Sys., Inc. v. Flowdata, Inc., 96 F.3d 1390, 1394 (Fed. Cir. 1996)), report and recommendation adopted, No. 3:12-CV-1984, 2016 WL 948878 (M.D. Pa. Mar. 14, 2016); see also Abdullah-Malik v. Bryant, No. 1:14-cv-109-RBH, 2015 WL 225740, at *3 (D.S.C. Jan. 16, 2015) (“[T]o the extent [Plaintiff] seeks to enjoin persons who are not parties to this lawsuit, Plaintiff’s motion is improper.”); U.S. Commodity Futures Trading Comm’n v. Amaranth Advisors, LLC, 523 F. Supp. 2d 328, 334 (S.D.N.Y. 2007) (denying defendant’s motion for a preliminary injunction against the Federal Energy Regulatory Commission because it was not a

party to the suit and it was not an “officer, agent, servant, employee, or attorney” of any party). Indeed, Defendants, as employees of FCI Bennettsville, presumably have no ability to control Plaintiff’s medical care at FCI Beckley, where he is now housed. See ECF No. 21 at 12. Accordingly, to the extent Plaintiff seeks to enjoin persons who are not parties to this lawsuit, the Motion should be denied. Further, a plaintiff seeking a preliminary injunction must establish all four of the following elements: (1) he is likely to succeed on the merits; (2) he is likely to suffer irreparable harm in the absence of preliminary relief; (3) the balance of equities tips in his favor; and (4) an injunction is in the public interest. Winter v. Nat. Res. Def. Council, Inc., 555 U.S. 7, 20 (2008). A plaintiff must make a clear showing that he is likely to succeed on the merits of his claim. Id. at 22. Similarly,

he must make a clear showing that he is likely to be irreparably harmed absent injunctive relief. Id. at 20–23. Only then may the court consider whether the balance of equities tips in the plaintiff’s favor. Finally, the court must particularly regard the public consequences of employing the extraordinary relief of injunction. Id. at 24. First, Plaintiff has failed to make a clear showing that he is likely to succeed on the merits of his claim or that he is likely to be irreparably harmed absent injunctive relief. Plaintiff’s allegations regarding his injuries implicate the Eighth Amendment. See Scinto v. Stansberry, 841 F.3d 219, 233 (4th Cir. 2016). The Eighth Amendment provides protection with respect to the conditions under which a prisoner is confined and the provision of medical care. See Helling v. McKinney, 509 U.S. 25, 31 (1993); Estelle v. Gamble, 429 U.S. 97, 104 (1976); see also Abraham v. McDonald, 493 F. App’x 465, 466 (4th Cir. 2012) (“A delay in treatment may constitute deliberate indifference if the delay exacerbated the injury or unnecessarily prolonged an inmate’s pain.”); Iko v. Shreve, 535 F.3d 225, 241 (4th Cir. 2008) (“[A] serious medical need is one that has

been diagnosed by a physician as mandating treatment or one that is so obvious that even a lay person would easily recognize the necessity for a doctor’s attention.” (internal quotation marks and alterations omitted)). Though Plaintiff alleges severe back pain resulting from an injury incurred at FCI Bennettsville, ECF No. 21 at 6, Plaintiff has not shown that he is being denied critical medical care for his condition. Plaintiff asserts he has not been seen by an outside doctor since his injury, see ECF No. 44 at 1, but he does not indicate he has not been seen at all. In fact, medical records provided by Defendants in response to Plaintiff’s Motion indicate Plaintiff was seen as recently as August 25, 2025. ECF No. 50-1 at 1–3.

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