Higdon v. Smith

CourtDistrict Court, S.D. Georgia
DecidedMay 1, 2020
Docket6:19-cv-00037
StatusUnknown

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

Bluebook
Higdon v. Smith, (S.D. Ga. 2020).

Opinion

IN THE UNITED STATES DISTRICT COURT FOR THE SOUTHERN DISTRICT OF GEORGIA STATESBORO DIVISION

ROMAN CHRISTIAN HIGDON,

Plaintiff, CIVIL ACTION NO.: 6:19-cv-37

v.

TAMARSHE SMITH; BRIAN COLLIER; and SGT. ROBINSON,

Defendants.

MAGISTRATE JUDGE’S REPORT AND RECOMMENDATION Plaintiff filed this action, asserting claims under 42 U.S.C. § 1983. Doc. 1. This matter is now before the Court for a frivolity screening under 28 U.S.C. § 1915A. For the reasons stated below, I RECOMMEND the Court DISMISS the following portions of Plaintiff’s Complaint: 1. Plaintiff’s claim against Defendant Robinson; and 2. Any claims for monetary relief against Defendants in their official capacities. However, I FIND some of Plaintiff’s claims may proceed. Specifically, the Court directs service, by separate Order, of Plaintiff’s Eighth Amendment claims of excessive force against Defendants Smith and Collier in their individual capacities. PLAINTIFF’S CLAIMS1 Plaintiff, who is presently confined at Hays State Prison in Trion, Georgia, brings this lawsuit under 42 U.S.C. § 1983 based on events that occurred at Smith State Prison in

1 During frivolity review under 28 U.S.C. § 1915A, “[t]he complaint’s factual allegations must be accepted as true.” Waldman v. Conway, 871 F.3d 1283, 1289 (11th Cir. 2017). Glennville, Georgia, in July 2017. Doc. 1. Plaintiff alleges that on July 25, 2017, Defendant Robinson ordered a lockdown to enable prison officials to search for a missing mop. Id. at 5. Plaintiff alleges the prisoners ultimately complied with the lockdown order and began returning to their cells. However, Defendant Robinson called in a “stress code,” and Defendant Smith, the

Deputy Warden of Security, sent a CERT Team in to assist with the lockdown process. Plaintiff specifically alleges that “Mr. Smith sent the CERT team down there to apply excessive force.” Id. Defendant Collier, who was part of the CERT team, began spraying prisoners, including Plaintiff, with MK-4 spray as they returned to their cells. Id. at 5–6. Plaintiff and the other prisoners began coughing and throwing up and were taken to medical. Id. at 6. The next morning, Plaintiff and his cellmate were transferred to a segregation unit with no running water. Plaintiff was not able to shower until several days later. Id. Plaintiff alleges the MK-4 spray that was used on him impacted his vision and damaged his lungs. As a result of the spray and not being able to wash it off for several days, Plaintiff

complains he no longer has 20/20 vision, he has difficulty breathing, and he now requires glasses and an inhaler. Id. at 7. He seeks compensatory and punitive damages from Defendants. Id. at 8. STANDARD OF REVIEW A federal court is required to conduct an initial screening of all prisoner complaints. 28 U.S.C. § 1915A(b). During the initial screening, the court must identify any cognizable claims in the complaint. Id. Additionally, the court must dismiss the complaint (or any portion of the complaint) that is frivolous, malicious, fails to state a claim upon which relief may be granted, or which seeks monetary relief from a defendant who is immune from such relief.2 Id. In its analysis, the Court will abide by the long-standing principle that the pleadings of unrepresented parties are held to a less stringent standard than those drafted by attorneys and, therefore, must be liberally construed. Haines v. Kerner, 404 U.S. 519, 520 (1972). However, Plaintiff’s

unrepresented status will not excuse mistakes regarding procedural rules. McNeil v. United States, 508 U.S. 106, 113 (1993). A claim is frivolous under § 1915(e)(2)(B)(i) if it is “without arguable merit either in law or fact.” Napier v. Preslicka, 314 F.3d 528, 531 (11th Cir. 2002) (quoting Bilal v. Driver, 251 F.3d 1346, 1349 (11th Cir. 2001)). In order to state a claim upon which relief may be granted, a complaint must contain “sufficient factual matter, accepted as true, to ‘state a claim to relief that is plausible on its face.’” Ashcroft v. Iqbal, 556 U.S. 662, 678 (2009) (quoting Bell Atl. Corp. v. Twombly, 550 U.S. 544, 570 (2007)). To state a claim, a complaint must contain “more than labels and conclusions, and a formulaic recitation of the elements of a cause of action will not” suffice. Twombly, 550 U.S. at 555. At this stage, the Court accepts as true a plaintiff’s factual

allegations. Waldman v. Conway, 871 F.3d 1283, 1289 (11th Cir. 2017). DISCUSSION I. Plaintiff’s Claim Against Defendant Robinson In his Complaint, Plaintiff alleges Defendant Robinson initiated the July 25, 2017 lockdown and called the stress code. Doc. 1 at 5. However, Plaintiff makes no allegation that Defendant Robinson participated in the spraying incident, and Plaintiff fails to attribute any specific constitutional violations or other causes of actions to Defendant Robinson. See generally Doc. 1.

2 Similarly, the Court must also conduct an initial screening of any action in which the plaintiff is proceeding in forma pauperis. 28 U.S.C. § 1915(a). “Section 1983 claims may not be brought against supervisory officials solely on the basis of vicarious liability or respondeat superior.” Averhart v. Warden, 590 F. App’x 873, 874 (11th Cir. 2014) (citing Keating v. City of Miami, 598 F.3d 753, 762 (11th Cir. 2010)). Rather, “[a] supervisor can be held liable under § 1983 if he personally participates in the alleged

constitutional violation or if a causal connection exists between his acts and the constitutional infirmity.” Id. “A causal connection can be established when a history of widespread abuse puts the responsible supervisor on notice of the need to correct the alleged deprivation and he fails to do so; when the supervisor’s improper custom or policy leads to deliberate indifference to constitutional rights; or when facts support an inference that the supervisor directed the subordinates to act unlawfully or knew that the subordinates would act unlawfully and failed to stop them from doing so.” Douglas v. Yates, 535 F.3d 1316, 1322 (11th Cir. 2008). Here, Plaintiff fails to allege any facts that could impose liability on Defendant Robinson. Defendant Robinson’s decision to call the stress code does not make him automatically liable for the subsequent events. As Plaintiff has failed to state a claim against Defendant Robinson, I

RECOMMEND the Court DISMISS Defendant Robinson from this action. II.

Free access — add to your briefcase to read the full text and ask questions with AI

Related

Bilal v. Driver
251 F.3d 1346 (Eleventh Circuit, 2001)
Louis Napier v. Karen J. Preslicka
314 F.3d 528 (Eleventh Circuit, 2002)
Douglas v. Yates
535 F.3d 1316 (Eleventh Circuit, 2008)
Keating v. City of Miami
598 F.3d 753 (Eleventh Circuit, 2010)
Haines v. Kerner
404 U.S. 519 (Supreme Court, 1972)
Thomas v. Arn
474 U.S. 140 (Supreme Court, 1986)
Will v. Michigan Department of State Police
491 U.S. 58 (Supreme Court, 1989)
McNeil v. United States
508 U.S. 106 (Supreme Court, 1993)
Alden v. Maine
527 U.S. 706 (Supreme Court, 1999)
Bell Atlantic Corp. v. Twombly
550 U.S. 544 (Supreme Court, 2007)
Ashcroft v. Iqbal
556 U.S. 662 (Supreme Court, 2009)
Derrick Averhart v. Warden
590 F. App'x 873 (Eleventh Circuit, 2014)
Vincent Vidal Mitchell v. United States
612 F. App'x 542 (Eleventh Circuit, 2015)
Maurice Symonette v. V.A. Leasing Corporation
648 F. App'x 787 (Eleventh Circuit, 2016)
Adam Keith Waldman v. Alabama Prison Commissioner
871 F.3d 1283 (Eleventh Circuit, 2017)
Free v. Granger
887 F.2d 1552 (Eleventh Circuit, 1989)

Cite This Page — Counsel Stack

Bluebook (online)
Higdon v. Smith, Counsel Stack Legal Research, https://law.counselstack.com/opinion/higdon-v-smith-gasd-2020.