HELMS v. WILLIAMS

CourtDistrict Court, D. New Jersey
DecidedSeptember 11, 2023
Docket1:22-cv-07519
StatusUnknown

This text of HELMS v. WILLIAMS (HELMS v. WILLIAMS) 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
HELMS v. WILLIAMS, (D.N.J. 2023).

Opinion

UNITED STATES DISTRICT COURT DISTRICT OF NEW JERSEY

JESSE HELMS, Civil Action Plaintiff, No. 22-7519 (CPO) (AMD)

v. OPINION AMANDA WILLIAMS,

Defendant. O’HEARN, District Judge. Plaintiff, who was a state inmate at the time he filed this case, is proceeding pro se with an Amended Complaint (hereinafter “Complaint”) pursuant to 42 U.S.C. § 1983. (ECF No. 11.) For the reasons stated in this Opinion, the Court will dismiss Plaintiff’s federal claim without prejudice and decline to exercise supplemental jurisdiction over his potential state law claims. I. BACKGROUND1 This case arises from Plaintiff’s medical treatment at South Woods State Prison, in Bridgeton, New Jersey. (ECF No. 11, at 5–6.) Plaintiff names only Amanda Williams, a nurse at the prison, as a Defendant in this matter. (Id. at 4.) Plaintiff contends that on November 17, 2022, he went out to the recreation area to play basketball. (Id. at 5.) During the game, Plaintiff landed on his hands and noticed that his right hand became swollen and difficult to move. (Id.) The next day, he sought medical attention. (Id.) Defendant Williams evaluated Plaintiff and asked him to explain his medical issue. (Id.) Plaintiff “told her [his] hand is caus[ing] him pain.” (Id.)

1 The Court will accept as true the factual allegations in the Complaint for the purposes of this screening only. The Court has made no findings as to the veracity of Plaintiff’s allegations. Defendant Williams “look[ed]” at his hand and said, “she can fix it.” (Id.) She took a hold of his hand and ring finger and asked him if he was ready. (Id.) She then “suddenly” pulled his ring finger, “causing it to crack[] very loudly,” and causing Plaintiff to nearly faint from pain. (Id.) She told Plaintiff that he was now “ok and can return to [his] unit.” (Id.) Within a week, however, Plaintiff was still having issues with his hand, and “it felt even worse than before.” (Id.) Plaintiff

anticipates having surgery at some point in the future. (Id. at 8.) Plaintiff filed his initial complaint in December of 2022, and the instant Complaint in May of 2023. In terms of relief, Plaintiff seeks compensation for his pain and suffering. (Id. at 7–8.) II. STANDARD OF REVIEW District courts must review complaints in civil actions in which a plaintiff is proceeding in forma pauperis and in which a plaintiff sues “a governmental entity or officer or employee of a governmental entity.” See 28 U.S.C. §§ 1915(e)(2)(B), 1915A(a). District courts must sua sponte dismiss any claim that is frivolous, is malicious, fails to state a claim upon which relief may be granted, or seeks monetary relief from a defendant who is immune from such relief. See 28 U.S.C.

§ 1915A(b). When considering a dismissal for failure to state a claim on which relief can be granted, courts apply the same standard of review as that for dismissing a complaint under Federal Rule of Civil Procedure 12(b)(6). Schreane v. Seana, 506 F. App’x 120, 122 (3d Cir. 2012). Consequently, 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 v. 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). Moreover, 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). III. DISCUSSION Plaintiff brings this action pursuant to 42 U.S.C. § 1983. To succeed on a § 1983 claim, a plaintiff must allege two things: first, a violation of a right under the Constitution, and second, that

a “person” acting under color of state law committed the violation. West v. Atkins, 487 U.S. 42, 48 (1988). Plaintiff argues that Defendant Williams denied him proper medical care, which may fall under the Eighth Amendment’s prohibition against cruel and unusual punishment. (ECF No. 11, at 4–5.) For the delay or denial of medical care to rise to a constitutional violation, a prisoner must demonstrate “(1) that defendants were deliberately indifferent to [his] medical needs and (2) that those needs were serious.” Rouse v. Plantier, 182 F.3d 192, 197 (3d Cir. 1999). Deliberate indifference requires proof that the official “knows of and disregards an excessive risk to inmate health or safety.” Natale v. Camden Cnty. Corr. Facility, 318 F.3d 575, 582 (3d Cir. 2003) (quoting

Farmer v. Brennan, 511 U.S. 825, 837 (1994)). More specifically, courts have found deliberate indifference where a person: “(1) knows of a prisoner’s need for medical treatment but intentionally refuses to provide it; (2) delays necessary medical treatment based on a nonmedical reason; or (3) prevents a prisoner from receiving needed or recommended treatment.” Rouse, 182 F.3d at 197. That said, courts give deference to prison medical authorities in the diagnosis and treatment of patients and will not “second-guess the propriety or adequacy of a particular course of treatment . . . [which] remains a question of sound professional judgment.” Inmates of Allegheny Cnty. Jail v. Pierce, 612 F.2d 754, 762 (3d Cir. 1979). As a result, allegations of medical malpractice or negligent treatment do not rise to constitutional violations. Estelle v. Gamble, 429 U.S. 97, 105– 06 (1976); Pierce v. Pitkins, 520 F. App’x 64, 66 (3d Cir. 2013) (per curiam). Applying those principles here, the Court will assume that Plaintiff’s swollen right hand satisfies the second Rouse prong, as a serious medical need. Rouse, 182 F.3d at 197. As to the first prong, however, the Complaint fails to allege facts to support a claim that Defendant Williams was

deliberately indifferent to that need. Rather, Plaintiff admits that Defendant Williams evaluated his hand on November 18, 2022, and tried to “fix it.” (ECF No. 11, at 5.) It appears that Defendant Williams believed that the finger was dislocated from the joint and attempted to relocate the finger. (See id.) It also appears, that she believed that she was successful in doing so. (See id.) Plaintiff contends that she “didn’t follow protocol dealing with broken bones and us[ed] bad judgment.” (Id. at 4.) Plaintiff’s disagreement with Defendant Williams as to the proper course of treatment does not rise to the level of an Eighth Amendment violation. See, e.g., Lenhart v. Pennsylvania, 528 F. App’x 111, 115 (3d Cir. 2013) (explaining that allegations of negligent diagnosing and treatment,

and mere disagreement as to proper medical treatment do not raise a constitutional claim); Smith v. O’Boyle, 251 F. App’x 87, 90 (3d Cir.

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Related

Estelle v. Gamble
429 U.S. 97 (Supreme Court, 1976)
West v. Atkins
487 U.S. 42 (Supreme Court, 1988)
Ashcroft v. Iqbal
556 U.S. 662 (Supreme Court, 2009)
Gary Rhines v. B. Bledsoe
388 F. App'x 225 (Third Circuit, 2010)
United States v. Fayette County, Pennsylvania
599 F.2d 573 (Third Circuit, 1979)
Hedges v. Musco
204 F.3d 109 (Third Circuit, 2000)
McCluskey v. Vincent
505 F. App'x 199 (Third Circuit, 2012)
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)
William Pierce v. David Pitkins
520 F. App'x 64 (Third Circuit, 2013)
Timothy Lenhart v. Commonwealth of Pennsylvania
528 F. App'x 111 (Third Circuit, 2013)
Farmer v. Brennan
511 U.S. 825 (Supreme Court, 1994)
Fowler v. UPMC SHADYSIDE
578 F.3d 203 (Third Circuit, 2009)
Natale v. Camden County Correctional Facility
318 F.3d 575 (Third Circuit, 2003)
Smith v. O'Boyle
251 F. App'x 87 (Third Circuit, 2007)

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HELMS v. WILLIAMS, Counsel Stack Legal Research, https://law.counselstack.com/opinion/helms-v-williams-njd-2023.