ELLISON v. NEW JERSEY STATE PRISON MEDICAL DEPARTMENT

District Court, D. New Jersey·Decided November 28, 2023·No. 3:20-cv-09465·Unknown

Opinion

NOT FOR PUBLICATION

UNITED STATES DISTRICT COURT DISTRICT OF NEW JERSEY

ARTHUR ELLISON, Plaintiff, Civil Action No, 20-9465 (ZNQ) (LHG) V. OPINION NEW JERSEY STATE PRISON MEDICAL DEPARTMENT, et al., Defendants.

QURAISHL District Judge Plaintiff Arthur Ellison, a convicted and sentenced prisoner at New Jersey State Prison in Trenton, New Jersey, is proceeding pro se with a civil rights complaint pursuant to 42 U.S.C. § 1983 and state law. (Compl., ECF No. 1.) Ina prior opinion, the Court dismissed all of Plaintiff's federal claims for failure to state a claim for relief and declined to exercise supplemental jurisdiction over Plaintiff's state law claims. (Jan, 23, 2023 Op., ECF No, 8.) Before the Court is Plaintiff's amended complaint. (Am. Compl., ECF No. 9.) For the reasons below, the Court once again dismisses all federal claims in the Amended Complaint without prejudice for failure to state a claim and declines to exercise supplemental jurisdiction over Plaintiff's remaining state law claims.

1, BACKGROUND AND PROCEDURAL HISTORY The Court set forth the facts underlying this matter at length in its January 23, 2023 Opinion and does not repeat them here. (See Jan. 23, 2023 Op.) In sum, this case arises from alleged inadequate treatment that Plaintiff received for a longstanding skin rash, (See id.) Plaintiff names, among others, various nurses and doctors who treated Plaintiff as defendants. On or around July 27, 2020, Plaintiff initiated this matter by filing a complaint with the Court, (Compl) The Court ultimately granted Plaintiff's application to proceed in forma pauperis and proceeded to screen the Complaint. (See Jan. 23, 2023 Op.) The Court construed the Complaint as asserting Eighth Amendment inadequate medical care claims brought pursuant to Section 1983 and state law claims for negligence and/or medical malpractice, (See id.) The Court dismissed all federal claims for failure to state a claim for relief and declined to exercise supplemental jurisdiction over Plaintiff's state law claims. (See id.) Plaintiff has since submitted an amended complaint, which this Court now screens pursuant to 28 U.S.C. § 1915(e)(2)(B). II. STANDARD OF REVIEW District courts must review complaints in civil actions in which a plaintiff is proceeding in forma pauperis, See 28 U.S.C. § 1915(e)(2)(B). District courts may sua sponte dismiss any claim that is frivolous, is malicious, fails to state a claim upon which the court may grant relief, or seeks monetary relief from a defendant who is immune from such relief. See id The legal standard for dismissing a complaint for failure to state a claim pursuant to Sections 1915(e)(2)(B) is the same as that for dismissing a complaint pursuant to Federal Rule of Civil Procedure 12(b)(6). Schreane v, Seana, 506 F. App’x 120, 122 (d Cir. 2012); Courteau v. United States, 287 F. App’x 159, 162 (3d Cir. 2008). A court properly grants a motion to dismiss pursuant to Rule 12(b)(6) if, accepting all well-pleaded allegations in the complaint as true, and

viewing them in the light most favorable to plaintiff, plaintiff is not entitled to relief. See Phillips, 515 F.3d at 233, To survive sua sponte screening for failure to state a claim, the complaint must allege “sufficient factual matter” to show that the claim is facially plausible. See Fowler vy. UPMC Shadyside, 578 F.3d 203, 210 (3d Cir, 2009). “A claim has facial plausibility when the plaintiff pleads factual content that allows the court to draw the reasonable inference that the defendant is liable for the [alleged] misconduct.” Ashcroft v. Iqbal, 556 U.S. 662, 678 (2009), While courts liberally construe pro se pleadings, “pro se litigants still must allege sufficient facts in their complaints to support a claim.” Mala v. Crown Bay Marina, Inc., 704 F.3d 239, 245 (3d Cir. 2013) (citation omitted). DISCUSSION The Court construes the Amended Complaint as setting forth the same claims as the original complaint, i.e., Eighth Amendment inadequate medical care claims brought pursuant to Section 1983 against each defendant and state law claims for negligence and/or medical malpractice. For the reasons below, however, the Court finds that the Amended Complaint fails to state an Eighth Amendment inadequate medical care claim, and the Court declines to exercise supplemental jurisdiction over Plaintiffs state law claims. A. Inadequate Medical Care Claims As the Court previously explained, the Eighth Amendment’s prohibition against cruel and unusual punishment requires that prison officials provide inmates with adequate medical care. Estelle v. Gamble, 429 U.S. 97, 103-04 (1976). To state a claim of inadequate medical care in violation of the Eighth Amendment, an inmate must generally allege facts showing (i) a serious

medical need, and (ii) acts or omissions by prison officials that indicate deliberate indifference to that need. /d at 106, A medical need is “serious” if it is “one that has been diagnosed by a physician as requiring treatment or one that is so obvious that a lay person would easily recognize the necessity for a doctor’s attention.” Monmouth County Corr. Inst. Inmates y. Lanzaro, 834 F.2d 326, 347 (3d Cir. 1987). A court may also determine the seriousness of the inmate’s medical need by reference to the effect of denying a particular treatment. /d. A condition is serious if denial of a particular treatment would cause death, degeneration, or extreme pain. See id. Deliberate indifference is a “subjective standard of liability consistent with reckless as that term is defined in criminal law.” See Nicini v, Morra, 212 F.3d 798, 811 (3d Cir. 2000) (emphasis added). To be liable, the prison official must know of and disregard an excessive risk to inmate health or safety; the official must be both aware of facts from which the inference could be drawn that a substantial risk of serious harm exists, and he must also draw the inference. Farmer v. Brennan, 511 U.S, 825, 836-37 (1994). A plaintiff, therefore, must plead enough factual matter to allow the court to infer reasonably that the official was subjectively aware of a substantial risk of serious harm and that the official disregarded that risk. See id.; Iqbal, 556 U.S. at 678. Moreover, “mere disagreement as to the proper medical treatment” is insufficient to support an Eighth Amendment claim. Lanzaro, 834 F.2d at 346. In cases where the complaint alleges inadequate medical treatment as opposed to a complete denial or delay of medical care, courts “presume that the treatment of a prisoner is proper absent evidence that it violates professional standards of care.” Pearson v. Prison Health Serv., 850 F.3d 526, 535 (3d Cir, 2017), Accordingly, at the pleading stage in such cases, “the plaintiff must allege that the treatment violated professional standards of care, in addition to alleging that the defendant acted with the

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ELLISON v. NEW JERSEY STATE PRISON MEDICAL DEPARTMENT, (D.N.J. 2023).

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Related

Estelle v. Gamble
429 U.S. 97 (Supreme Court, 1976)
Ashcroft v. Iqbal
556 U.S. 662 (Supreme Court, 2009)
Nicini v. Morra
212 F.3d 798 (Third Circuit, 2000)
Clarence Schreane v. Seana
506 F. App'x 120 (Third Circuit, 2012)
Kelley Mala v. Crown Bay Marina
704 F.3d 239 (Third Circuit, 2013)
Fowler v. UPMC SHADYSIDE
578 F.3d 203 (Third Circuit, 2009)
Courteau v. United States
287 F. App'x 159 (Third Circuit, 2008)
Antonio Pearson v. Prison Health Service
850 F.3d 526 (Third Circuit, 2017)