GRIGGER v. MERCER COUNTY CORRECTIONAL

CourtDistrict Court, D. New Jersey
DecidedJuly 8, 2022
Docket3:20-cv-14491
StatusUnknown

This text of GRIGGER v. MERCER COUNTY CORRECTIONAL (GRIGGER v. MERCER COUNTY CORRECTIONAL) is published on Counsel Stack Legal Research, covering District Court, D. New Jersey primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
GRIGGER v. MERCER COUNTY CORRECTIONAL, (D.N.J. 2022).

Opinion

UNITED STATES DISTRICT COURT DISTRICT OF NEW JERSEY

FREDERICK E. GRIGGER, JR., Civil Action No. 20-14491 (FLW)

Plaintiff, MEMORANDUM & ORDER v.

MERCER COUNTY CORRECTIONAL, et al.,

Defendants.

Plaintiff has filed a Complaint alleging violations of his civil rights pursuant to 42 U.S.C. § 1983, and the Court previously granted Plaintiff’s IFP application. See ECF Nos. 1-2. Federal law requires this Court to screen Plaintiff’s Complaint for sua sponte dismissal prior to service, and to dismiss any claim if that claim fails to state a claim upon which relief may be granted under Fed. R. Civ. P. 12(b)(6) and/or to dismiss any defendant who is immune from suit. See 28 U.S.C. § 1915(e)(2)(B); Tourscher v. McCullough, 184 F.3d 236, 240 (3d Cir. 1999). The legal standard for dismissing a complaint for failure to state a claim pursuant to 28 U.S.C. § 1915(e)(2)(B)(ii) is the same as the standard for dismissing a complaint pursuant to Federal Rule of Civil Procedure 12(b)(6). Schreane v. Seana, 506 F. App’x 120, 122 (3d Cir. 2012). That standard is set forth in Ashcroft v. Iqbal, 556 U.S. 662 (2009), and Bell Atlantic Corp. v. Twombly, 550 U.S. 544 (2007). To survive screening, Plaintiff’s Complaint must contain “sufficient factual matter, accepted as true, to state a claim to relief that is plausible on its face.” Iqbal, 556 U.S. at 678 (quotations omitted). Conclusory allegations do not suffice. See id. Because Plaintiff is proceeding pro se, the Court construes his allegations liberally. See Higgs v. Att’y Gen., 655 F.3d 333, 339 (3d Cir. 2011). Plaintiff’s Complaint is not a model of clarity, but he appears to allege that various state officials and Mercer County Correctional Center (“MCCC”) violated his constitutional rights by denying him bail and ignoring unsafe conditions at MCCC during the COVID-19 pandemic. Plaintiff alleges that former Attorney General Gurbir Grewal (“Grewal”) failed to ensure that prosecutors were following Executive Order # 1031 and releasing inmates due to the dangers

of COVID-19. See Complaint at 6. Grewal also allegedly ignored the seriousness of COVID- 19. Id. According to the Complaint, Grewal’s prosecutors testified at Plaintiff’s bail hearing on August 10, 2020, that Plaintiff would be safe from COVID-19. Complaint at 9. Plaintiff allegedly wrote to Grewal, but he received no response. Id. Plaintiff alleges that Governor Phil Murphy (“Murphy”) also failed to ensure that Executive Order # 103 was followed and failed the brief the public about the conditions at Mercer County Jail. See Complaint at 6. Murphy allegedly ignored the health and safety of pretrial detainees at the county jails when he issued executive orders related to COVID-19. Id. at 11. Plaintiff appears to allege that the executive orders issued by Murphy were deficient with

respect to pretrial detainees in the county jails and/or those inmates under the age of 60 years old. Id. at 11. Plaintiff further alleges that the bail reform system is a “failure in whole.” Id. Plaintiff also alleges that Mike Mennuti (“Mennuti”), the prosecutor in Plaintiff’s criminal case, failed to follow Executive Order # 103 and recommend releasing Plaintiff on bail due to the dangers of COVID-19, despite the fact that Plaintiff was charged with a third-degree crime and had “a 3-4 score.” Mennuti also “downplayed” the danger of COVID-19. Id. at 13.

1 Executive Order 103, issued by Governor Philip D. Murphy on March 9, 2020, declared the existence of a Public Health Emergency in the State for COVID-19. Plaintiff alleges that Brian Hughes (“Hughes”) failed to manage MCCC in a safe manner during the COVID-19 pandemic and is responsible for numerous health and safety violations. Id. at 12. Plaintiff wrote to Hughes, but he failed to respond. See Complaint at 6, 11. Plaintiff has also sued Warden Charles Ellis for failing to adhere to CDC guidelines for

social distancing at MCCC and for reporting “false information.” Plaintiff also complains about a lack of “mask exchange,” a lack of running showers, no water fountains on units, lack of testing, lack of medical help from CFH Health Services staff, and lack of information about COVID-19, but he provides few facts about these conditions.2 See id. at 7. Plaintiff has also sued “[MCCC] (Freeholders)” for failing to have a facility free of serious defects that might harm inmates health and safety. See Complaint at 6. Plaintiff is seeking damages for “long or short term medical health[,]” Complaint at 8, but he does not provide any facts to suggest that he has any high risk medical conditions or that he suffered any medical issues at MCCC as a result of contracting COVID-19 or otherwise. At the time, he filed his Complaint, Plaintiff was a pretrial detainee. Plaintiff’s IFP

application lists his date of detention at MCCC as February 29, 2020. See ECF No. 1-2 at 2. After he submitted his Complaint, Plaintiff updated his address to Bayside State Prison. It appears that Plaintiff was convicted of aggravated assault in violation of N.J.S.A. 2C:12-1(b),

2 Plaintiff also submitted an unsigned type-written letter dated July 23, 2020, that is addressed “To whom it may concern[.]” ECF No. 1-3. The letter lists purported safety violations at MCCC in connection with the COVID-19 pandemic. See id. Because this letter is unsigned and does not contain any allegations specific to Plaintiff, the Court declines to construe the letter as part of Plaintiff’s Complaint. Plaintiff is free to submit an Amended Complaint that includes some or all of the issues in the letter, with proper factual support, to the extent Plaintiff experienced these issues while confined at MCCC. and was sentenced to a four-year term of imprisonment on April 22, 2021.3 In total, it appears that Plaintiff was incarcerated as a pretrial detainee at MCCC for approximately 14 months. The Court construes Plaintiff to assert violations of his constitutional rights pursuant to 42 U.S.C. § 1983. To succeed on a claim under 42 U.S.C. § 1983, a plaintiff must show: (1) the

conduct complained of was committed by a person acting under color of state law; and (2) the conduct deprived the plaintiff of a federally secured right. See, e.g., Moore v. Tartler, 986 F. 2d 682, 685 (3d Cir. 1983). The Court first construes Plaintiff to allege that the failure to release him on bail during the COVID-19 pandemic violated his right to due process under the Fourteenth Amendment. It is well-established that pretrial detention implicates a liberty interest entitled to due process protections. United States v. Delker, 757 F.2d 1390, 1397 (3d Cir. 1985). Here, however, Plaintiff does not allege that he was denied a bail hearing or that he was denied any procedural safeguards during his bail hearing. See, e.g., U.S. v.

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GRIGGER v. MERCER COUNTY CORRECTIONAL, Counsel Stack Legal Research, https://law.counselstack.com/opinion/grigger-v-mercer-county-correctional-njd-2022.