Jackson v. United States

CourtDistrict Court, S.D. Texas
DecidedApril 4, 2025
Docket4:22-cv-01767
StatusUnknown

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

Bluebook
Jackson v. United States, (S.D. Tex. 2025).

Opinion

IN THE UNITED STATES DISTRICT COURT April 10, 2025 FOR THE SOUTHERN DISTRICT OF TEXAS Nathan Ochsner, Clerk HOUSTON DIVISION

PATRICK ALAN JACKSON, § BOP # 26361-078 § § Plaintiff, § § v. § CIVIL ACTION NO. H-22-1767 § UNITED STATES, § § Defendant. §

MEMORANDUM OPINION AND ORDER

The plaintiff, Patrick Alan Jackson, originally filed this suit while he was a federal inmate in the custody of the Bureau of Prisons. Because Jackson was a prisoner seeking relief under federal law at the time this lawsuit was filed, the court is required to closely examine his claims and dismiss the complaint if it determines that it is frivolous, malicious, or fails to state a claim upon which relief may be granted. See 42 U.S.C. § 1997e(c). Based on this review, the court dismisses this action, for the reasons explained below. I. Background

As noted, Jackson originally filed this suit while he was a federal inmate in the custody of the BOP. In his first amended complaint, he sued the United States under the Federal Tort Claims Act over medical care he received for an eye infection suffered while he was held at the Federal Detention Center in Houston (FDC Houston). (Docket Entry No. 11). He alleged negligence and medical malpractice based on delay in providing him treatment before he received eye surgery that addressed the problem. (Id.). The government moved to dismiss or for summary judgment on the grounds that the FTCA does not apply because the acts and omissions alleged were by an independent medical care contractor (WellPath), not FDC Houston, and that the pleadings were inadequate to state a negligence claim against any of the FDC Houston employees. (Docket Entry No. 19). In his response to the government’s motion, Jackson clarified that he is not alleging that he was injured by the acts or omissions of WellPath. Instead, he alleged for the first time that the FDC Houston employees failed to transport him to his medical appointments. (See Docket Entry No. 23). Relying on Fifth Circuit law, the court liberally construed Jackson’s response to the

government’s motion, in which he asserted this new allegation, as a motion for leave to amend his complaint. (See Docket Entry No. 26). Jackson was given 30 days to file a second amended complaint. (See id.). On Jackson’s motions for additional time, the court granted him an additional 120 days to file a second amended complaint. (See Docket Entry Nos. 28, 30, 33). In Jackson’s second amended complaint, he names only one defendant, WellPath. (Docket Entry No. 34). (See id.). Construing the complaint liberally, Jackson asserts claims under the FTCA and the Eighth and Fourteenth Amendments to the United States Constitution. II. The Legal Standards

A. Screening Under 28 U.S.C. § 1915A

Because Jackson was a prisoner at the time this lawsuit was filed, the Prison Litigation Reform Act requires the court to scrutinize the pleadings. The court must dismiss any part of the case that it determines is frivolous, malicious, fails to state a claim on which relief may be granted, or seeks monetary relief against a defendant who is immune from such relief. See 42 U.S.C. § 1997e(c). A complaint fails to state a claim upon which relief can be granted if it does not contain “sufficient factual matter, accepted as true, to state a claim to relief that is plausible on its face.” Rogers v. Boatright, 709 F.3d 403, 407 (5th Cir. 2013) (quoting Ashcroft v. Iqbal, 556 U.S. 662, 678 (2009)). Under this standard, the court “construes the complaint liberally in favor of the plaintiff,” “takes all facts pleaded in the complaint as true,” and considers whether “with every doubt resolved on [the plaintiff’s] behalf, the complaint states any valid claim for relief.” Harrington v. State Farm Fire & Cas. Co., 563 F.3d 141, 147 (5th Cir. 2009) (cleaned up). B. Pleadings from Self-Represented Litigants

Jackson is representing himself. Courts construe pleadings filed by self-represented litigants under a less stringent standard of review. See Haines v. Kerner, 404 U.S. 519, 520 (1972) (per curiam). Under this standard, “[a] document filed pro se is ‘to be liberally construed,’ and ‘a pro se complaint, however inartfully pleaded, must be held to less stringent standards than formal pleadings drafted by lawyers.’” Erickson v. Pardus, 551 U.S. 89, 94 (2007) (per curiam) (quoting Estelle v. Gamble, 429 U.S. 97, 106 (1976)). But even under this liberal standard, self-represented litigants must still “abide by the rules that govern the federal courts.” E.E.O.C. v. Simbaki, Ltd., 767 F.3d 475, 484 (5th Cir. 2014). They must “properly plead sufficient facts that, when liberally construed, state a plausible claim to relief, serve defendants, obey discovery orders, present summary judgment evidence, file a notice of appeal, and brief arguments on appeal.” Id. (cleaned up).

III. Discussion

As part of its screening obligation, the court must determine whether it has subject-matter jurisdiction over this case. “Federal courts are courts of limited jurisdiction. They possess only that power authorized by Constitution and statute, which is not to be expanded by judicial decree.” Kokkonen v. Guardian Life Ins. Co. of Am., 511 U.S. 375, 377 (1994) (citations omitted). District courts “must presume that a suit lies outside this limited jurisdiction, and the burden of establishing federal jurisdiction rests on the party seeking the federal forum.” Howery v. Allstate Ins. Co., 243 F.3d 912, 916 (5th Cir. 2001). A federal court has a duty to examine, at any time during a proceeding, the threshold question of whether it has subject-matter jurisdiction. See Ruhgras AG v. Marathon Oil Co., 526 U.S. 574, 583 (1999) (“[S]ubject-matter delineations must be policed by the courts on their own initiative even at the highest level.”); McDonal v. Abbott Labs., 408 F.3d 177, 182 n.5 (5th Cir. 2005) (“[A] federal court may raise subject matter jurisdiction sua sponte.”); Fed. R. Civ. P. 12(h)(3) (“If the court determines at any time that it lacks subject-matter jurisdiction, the court must dismiss the action.”).

A. Claims Asserted Under the FTCA

The FTCA authorizes claims against the United States that arise from “the negligent or wrongful act or omission of any employee of [a federal] agency while acting within the scope of his office or employment. . . .” 28 U.S.C. § 2672 (emphasis added).

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

Related

Linkous v. USA
142 F.3d 271 (Fifth Circuit, 1998)
Howery v. Allstate Ins Company
243 F.3d 912 (Fifth Circuit, 2001)
McDonal Ex Rel. McDonal v. Abbott Laboratories
408 F.3d 177 (Fifth Circuit, 2005)
Harrington v. State Farm Fire & Casualty Co.
563 F.3d 141 (Fifth Circuit, 2009)
Peacock v. United States
597 F.3d 654 (Fifth Circuit, 2010)
Creel v. United States
598 F.3d 210 (Fifth Circuit, 2010)
Haines v. Kerner
404 U.S. 519 (Supreme Court, 1972)
Estelle v. Gamble
429 U.S. 97 (Supreme Court, 1976)
Lugar v. Edmondson Oil Co.
457 U.S. 922 (Supreme Court, 1982)
Kokkonen v. Guardian Life Insurance Co. of America
511 U.S. 375 (Supreme Court, 1994)
Ruhrgas Ag v. Marathon Oil Co.
526 U.S. 574 (Supreme Court, 1999)
Erickson v. Pardus
551 U.S. 89 (Supreme Court, 2007)
Ashcroft v. Iqbal
556 U.S. 662 (Supreme Court, 2009)
Menteer v. Applebee
196 F. App'x 624 (Tenth Circuit, 2006)
Jasper v. Federal Emergency Management Agency
414 F. App'x 649 (Fifth Circuit, 2011)
Bruce Rogers v. Shawna Boatright
709 F.3d 403 (Fifth Circuit, 2013)
Phillip Turner v. Driver
848 F.3d 678 (Fifth Circuit, 2017)

Cite This Page — Counsel Stack

Bluebook (online)
Jackson v. United States, Counsel Stack Legal Research, https://law.counselstack.com/opinion/jackson-v-united-states-txsd-2025.