Griffin v. County of Mahoning

CourtDistrict Court, N.D. Ohio
DecidedFebruary 29, 2024
Docket4:23-cv-01920
StatusUnknown

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

Bluebook
Griffin v. County of Mahoning, (N.D. Ohio 2024).

Opinion

PEARSON, J. UNITED STATES DISTRICT COURT NORTHERN DISTRICT OF OHIO EASTERN DIVISION TRAVONTE GRIFFIN, ) ) CASE NO. 4:23 CV 1920 Plaintiff, ) ) v. ) JUDGE BENITA Y. PEARSON ) COUNTY OF MAHONING, et al., ) ) MEMORANDUM OF OPINION Defendants. ) AND ORDER I. Background Pro se Plaintiff Travonte Griffin, a convicted and sentenced federal prisoner, has filed an in forma pauperis prisoner civil rights complaint in this case under 42 U.S.C. § 1983 against the County of Mahoning; Mahoning County Commissioners “Mr. Traffitanti,” “Mr. Ditzler,” and “Ms. Rimedio-Righettetti”;1 Mahoning County Sheriff Jerry Greene; Mahoning County Justice Center Warden Captain Kountz; Sgts. Graham, Wallace, and McCullough; “MCJC Food Services/Dietician;” “MCJC Operations;” and “MCJC Administration.” ECF No. 1. The Complaint concerns the conditions of his confinement in the Mahoning County Justice Center (the “Jail” or “MCJC”). In his Complaint, Plaintiff generally complains the Jail is “over-crowded,” “under-staffed,” and “dangerous;” that two men are locked in a cell designed for one person for 15 hours per day with a toilet that is “backed up [and] won’t flush;” and that there is “no fruit or fish on [the] menu” and “no law library.” ECF No. 1-1 at PageID #: 7. 1Plaintiff did not originally state the names of the Commissioners in his Complaint, but he subsequently filed a motion to amend his Complaint to identify them by name (ECF No. 3), which motion is granted. 4:23CV 1920 Contending these conditions amount to cruel and unusual punishment and deprive him of his constitutional right of access to the courts, he seeks injunctive and monetary relief. II. Standard of Review Although federal courts are obligated to construe pro se complaints liberally, see Williams v. Curtin, 631 F.3d 380, 383 (6" Cir. 2011), such principles are not without limits. See Young Bok Ong v. Gipson, 423 F. App’x 506, 510 (6" Cir. 2011). Plaintiffs proceeding pro se must still meet basic pleading requirements, and courts are not required to “conjure allegations on [their] behalf.” Erwin v. Edwards, 22 F. App’x 579, 580 (6" Cir. 2001). Federal district courts are expressly required, under 28 U.S.C. $ 1915(e), to screen all in forma pauperis complaints filed in federal court and to dismiss before service any such action that the court determines is frivolous or malicious, fails to state a claim upon which relief may be granted, or seeks monetary damages from a defendant who is immune from such relief. See Hill y. Lappin, 630 F.3d 468, 470-71 (6th Cir. 2010) (holding that the dismissal standard articulated in Ashcroft v. Igbal, 556 U.S. 662 (2009) and Bell Atlantic Corp. v. Twombly, 550 U.S. 544 (2007) governs dismissals for failure to state a claim under 28 U.S.C. $ 1915(e)(2)(B)). To avoid a dismissal for failure to state a claim, “a complaint must contain sufficient factual matter, accepted as true, to ‘state a claim to relief that is plausible on its face.’” Igbal, 556 U.S. at 678 (quoting Twombly, 550 U.S. at 570). The factual allegations in the pleading “must be enough to raise the right to relief above the speculative level . . . on the assumption that all the allegations in the complaint are true (even if doubtful in fact).” Twombly, 550 U.S. at 555.

4:23CV 1920 To state a claim under § 1983, a plaintiff must allege and prove that he was deprived of a right secured by the Constitution or laws of the United States caused by a person acting under color of state law. Christy v. Randlett, 932 F.2d 502, 504 (6th Cir. 1991). Ill. Analysis Having reviewed Plaintiff’ s filings, the Court finds that his allegations are insufficient to state a plausible claim upon which he may be granted relief. First, to the extent he seeks injunctive relief, his claims are moot as the docket now indicates he is no longer confined in the Jail. See ECF No. 4; Kensu v. Haigh, 87 F.3d 172, 175 (6" Cir. 1996). Second, to the extent he seeks monetary relief, his Complaint fails to state a plausible constitutional claim against any Defendant. 1. Conditions of Confinement It is well-established that the Constitution “does not mandate comfortable prisons.” Wilson v. Seiter, 501 U.S. 294, 298 (1991). “[R]outine” discomforts of prison life do not suffice to state a claim of cruel and unusual punishment under the Constitution because such “discomfort is “part of the penalty that criminal offenders pay for their offenses against society.’” Hudson v. McMillian, 503 U.S. 1, 9-10 (1992), citing Rhodes v. Chapman, 452 U.S. 337, 347 (1981). Prison conditions rise to the level of a constitutional violation only when they involve the “wanton and unnecessary infliction of pain,” or concern “deprivations of essential food, medical care, or sanitation” or “other conditions intolerable for prison confinement.” Rhodes, 452 U.S. at 348. See also Ivey v. Wilson, 832 F.2d 950, 954 (6" Cir. 1987) (“Not every unpleasant

4:23CV 1920 experience a prisoner might endure while incarcerated constitutes cruel and unusual punishment within the meaning of the Eighth Amendment.”). Prison overcrowding, standing alone, does not violate the Constitution. See Rhodes, 452 U.S. at 348; Agramonte v. Shartle, 491 F. App'x 557, 560 (6th Cir. 2012) ("Overcrowding is not, in and of itself, a constitutional violation."). Rather, a plaintiff bears the burden of demonstrating that overcrowded or other general conditions led to independent deprivations of essential food, medical care, sanitation, other necessities. Rhodes, 452 U.S. at 348. Plaintiffs allegations are insufficient to make this showing. The Supreme Court has held that double-bunking, or double-celling, as Plaintiff alleges here does not violate the Constitution. See Bell v. Wolfish, 441 U.S. 535, 541-43 1979) (holding that double-bunking of detainees in cells originally designed for one person for several months does not violate the Constitution); Halliburton v. Sundquist, 59 F. App'x 781, 782 (6th Cir. 2003). Further, while basic decencies should be observed, the Sixth Circuit has recognized on more than one occasion that the Constitution is not violated by a prisoner’s temporary placement in a cell with a non-flushable toilet. See, e.g., Dellis v. Corrections Corp. of America, 257 F.3d 508, 511 (6th Cir. 2001) (citing Rhodes, 452 U.S. at 347) (a prisoner's claims alleging that he was deprived of a lower bunk, subjected to a flooded cell, and deprived of a working toilet amounted to "only temporary inconveniences and did not demonstrate that [his] conditions fell beneath the minimal civilized measure of life's necessities as measured by a contemporary standard of decency"); Abdur-Reheem-X vy. McGinnis, 193 F.3d 244 (Table), 1999 WL 1045069, at *2 (6th Cir. Nov. 12, 1999) (the Constitution "does not require that prisoners enjoy immediately

4:23CV1920 available and flushable toilets"); Knop v. Johnson, 977 F.2d 996, 1013 (6th Cir.

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Related

Rizzo v. Goode
423 U.S. 362 (Supreme Court, 1976)
Bounds v. Smith
430 U.S. 817 (Supreme Court, 1977)
Rhodes v. Chapman
452 U.S. 337 (Supreme Court, 1981)
Wilson v. Seiter
501 U.S. 294 (Supreme Court, 1991)
Hudson v. McMillian
503 U.S. 1 (Supreme Court, 1992)
Lewis v. Casey
518 U.S. 343 (Supreme Court, 1996)
Bell Atlantic Corp. v. Twombly
550 U.S. 544 (Supreme Court, 2007)
Ashcroft v. Iqbal
556 U.S. 662 (Supreme Court, 2009)
Jones v. Muskegon County
625 F.3d 935 (Sixth Circuit, 2010)
Hill v. Lappin
630 F.3d 468 (Sixth Circuit, 2010)
Williams v. Curtin
631 F.3d 380 (Sixth Circuit, 2011)
Alford Lee Cunningham v. Russell Jones, Jailer
567 F.2d 653 (Sixth Circuit, 1977)
Bellamy v. Bradley
729 F.2d 416 (Sixth Circuit, 1984)
Karen Christy v. James R. Randlett
932 F.2d 502 (Sixth Circuit, 1991)
Diane Knott v. Mark Sullivan
418 F.3d 561 (Sixth Circuit, 2005)
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Bluebook (online)
Griffin v. County of Mahoning, Counsel Stack Legal Research, https://law.counselstack.com/opinion/griffin-v-county-of-mahoning-ohnd-2024.