Craighead v. King

CourtDistrict Court, W.D. Virginia
DecidedSeptember 30, 2021
Docket7:20-cv-00356
StatusUnknown

This text of Craighead v. King (Craighead v. King) is published on Counsel Stack Legal Research, covering District Court, W.D. Virginia primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Craighead v. King, (W.D. Va. 2021).

Opinion

IN THE UNITED STATES DISTRICT COURT FOR THE WESTERN DISTRICT OF VIRGINIA ROANOKE DIVISION

XAVIER K-JUAN RASADON CRAIGHEAD, ) ) Plaintiff, ) Civil Action No. 7:20-cv-00356 ) v. ) MEMORANDUM OPINION ) HAROLD W. CLARKE, et al., ) By: Hon. Thomas T. Cullen ) United States District Judge Defendants. )

Xavier K-Juan Rasadon Craighead (“Craighead” or “Plaintiff”), a Virginia inmate incarcerated at Wallens Ridge State Prison (“Wallens Ridge”) and proceeding pro se, filed this civil action under 42 U.S.C. § 1983 against seven employees of the Virginia Department of Corrections (“VDOC”) (collectively, “Defendants”), alleging violations of his rights under the Eighth Amendment. This matter is before the court on Defendants’ motion to dismiss. After reviewing the pleadings, the court concludes that Craighead’s complaint fails to state a plausible claim against Defendants Clarke, Robinson, Manis,1 Zook, or Anderson, and will grant the motion to dismiss as to those Defendants. But the court concludes that Plaintiff has alleged facts sufficient to state plausible § 1983 claims for violations of Craighead’s Eighth Amendment rights against Defendants King and Woodward; Defendants’ motion will be denied as to those defendants.

1 Plaintiff misspelled the name Defendant Manis. The clerk will be directed to update the docket to reflect that defendant “Manias” should be spelled as “Manis.” I. CRAIGHEAD’S ALLEGATIONS

In a verified complaint filed on June 19, 2020, Craighead alleges that at about 1:30 p.m. on December 2, 2019, the cell doors in his pod were opened to permit the inmates to congregate for recreation. As Craighead entered the common area of his pod, a fight broke out between two inmates, about 10 feet away from him. Defendant Woodward and other correctional officers responded to the fight. Craighead alleges that Woodward shot an “impact round”2 without warning, hitting Craighead on the right side of his face. Craighead also alleges that, as correctional officers entered the pod to identify who was fighting, Defendant King, the Incident Captain, “pointed out” Craighead.3

Craighead was then taken for medical attention, and Defendants King and Anderson spoke to Craighead before he was returned to the pod. Craighead alleges that Anderson—who was a Major on the correctional staff at that time4—and King told Craighead he would not be returned to the pod until review of camera video confirmed that Craighead was not involved in the fight. The video evidence evidently confirmed that Craighead was not involved, and Craighead was returned to the pod a few minutes later.

Later that evening, Craighead was taken off-site for further medical attention. He received follow-up medical care at the prison the next day and additional off-site medical care

2 Although Craighead does not describe or define the “impact round,” the court notes that an “impact round” is typically a non-lethal projectile, such as a beanbag or rubber bullet, fired from a modified firearm.

3 The court infers from this allegation that Craighead alleges King unjustifiably suspected Craighead of participating in the fight, or perhaps that King directed—or misdirected—Woodward’s fire toward Craighead.

4 He is now an assistant Warden. on December 6, 2019. Although Craighead’s complaint references exhibits from his medical records, the referenced exhibits were not attached to his Complaint. But Craighead did attach medical records to his response to Defendants’ motion to

dismiss.5 According to those records, Craighead suffered a fracture of his facial bone, and his right eye and the right side of his face were swollen. Craighead experienced continuing numbness on the right side of his face through at least January 8, 2020. It is unclear from these medical records whether Craighead’s vision was affected. Separately, Craighead alleges that on July 20, 2017, he was assaulted by multiple officers, including Defendant King, while he was being placed in segregation. The assault and his

injuries were not documented. Craighead alleges that, from the time of the 2017 assault to the December 2, 2019 incident, he has been harassed and verbally assaulted.6 Craighead does not make any factual allegations regarding the remaining Defendants: Harold W. Clarke, the Director of VDOC; David Robinson, the Chief of Operations of VDOC; K. Manis, the Warden of Wallens Ridge at the date of incident; or David Zook, the current Warden of Wallens Ridge.

As his causes of action, Craighead claims that Defendant Woodward used excessive force without need or provocation, maliciously and sadistically, constituting cruel and unusual punishment in violation of the Eighth Amendment. Craighead further alleges that the other

5 Although outside evidence is typically not considered under Rule 12(b)(6) unless the motion is converted to one for summary judgment under Rule 56, the court may nevertheless consider documents reference in, but not attached to, a plaintiff’s complaint. See, e.g., Gasner v. Cnty. of Dinwiddie, 162 F.R.D. 280, 282 (E.D. Va. 1995) (“Cases from around the nation suggest that most courts have declared such reliance permissible without converting the motion into one for summary judgment.” (collecting cases)).

6 Craighead references an exhibit related to the 2017 incident, or perhaps to the alleged harassment and verbal assault. But the referenced exhibit was not included with his complaint. Defendants were deliberately indifferent and/or that they collectively failed to discipline correctional staff to curb a pattern of improper use of excessive force. Craighead contends that this constitutes deliberate indifference to himself and other prisoners, and contributed to

and was a proximate cause of Defendant Woodward’s assault and violation of Craighead’s Eighth Amendment rights. Craighead further alleges state-law tort claims against all Defendants. Craighead also claims that he has been and will continue to be irreparably injured—both mentally and physically—by Defendants’ conduct. Craighead seeks declaratory and injunctive relief, as well as compensatory, punitive, and nominal damages. II. STANDARD OF REVIEW

In order to allow for the development of a potentially meritorious claim, federal courts have an obligation to construe pro se pleadings liberally. See, e.g., Boag v. MacDougall, 454 U.S. 364, 365 (1982). Moreover, “[l]iberal construction of the pleadings is particularly appropriate where . . . there is a pro se complaint raising civil rights issues.” Smith v. Smith, 589 F.3d 736, 738 (4th Cir. 2009). Nevertheless, “[p]rinciples requiring generous construction of pro se complaints are not . . . without limits.” Beaudett v. City of Hampton, 775 F.2d 127, 1278 (4th Cir.

1985). “A pro se plaintiff still must allege facts that state a cause of action.” Bracey v. Buchanan, 55 F. Supp. 2d 416, 421 (E.D. Va. 1999). A motion to dismiss pursuant to Federal Rule of Civil Procedure 12(b)(6) tests the legal sufficiency of a complaint to determine whether the plaintiff has properly stated a claim. Republican Party of N.C. v. Martin, 980 F.2d 943, 952 (4th Cir. 1992). “[I]t does not resolve contests surrounding the facts, the merits of a claim, or the applicability of defenses.” Id. In

considering a Rule 12(b)(6) motion, a court must accept all factual allegations in the complaint as true and must draw all reasonable inferences in favor of the plaintiff. Erickson v.

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