James P. Abrams v. David Paul, Warden, et al.

CourtDistrict Court, E.D. Kentucky
DecidedNovember 19, 2025
Docket5:25-cv-00285
StatusUnknown

This text of James P. Abrams v. David Paul, Warden, et al. (James P. Abrams v. David Paul, Warden, et al.) is published on Counsel Stack Legal Research, covering District Court, E.D. Kentucky primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
James P. Abrams v. David Paul, Warden, et al., (E.D. Ky. 2025).

Opinion

UNITED STATES DISTRICT COURT EASTERN DISTRICT OF KENTUCKY CENTRAL DIVISION LEXINGTON

JAMES P. ABRAMS, ) ) Plaintiff, ) Civil Action No. 5:25-cv-00285-GFVT ) v. ) ) DAVID PAUL, WARDEN, et al., ) MEMORANDUM OPINION ) & ORDER Defendants. )

*** *** *** *** Plaintiff James P. Abrams is an inmate at the Federal Medical Center in Lexington, Kentucky (“FMC Lexington”). Proceeding without counsel, Abrams filed a civil rights complaint on August 13, 2025. [R. 1]. The Court screened Abrams’s complaint pursuant to 28 U.S.C. §§ 1915(e)(2) and 1915A and dismissed several of his claims. [R. 7]. However, the Court permitted him to proceed with his Bivens claims against Defendants Assistant Warden Sizemore and Ms. Mattingly. Since Abrams is a prisoner who is permitted to proceed in forma pauperis, the United States Marshals Service served Sizemore and Mattingly with a copy of the complaint and a summons on Abrams’s behalf. [R. 9]. Abrams has now filed an amended complaint [R. 28], which the Court will review under §§ 1915(e)(2) and 1915A. These provisions require dismissal of any claim that is frivolous, malicious, fails to state a claim upon which relief can be granted, or seeks monetary relief from a defendant who is immune to such relief. See also McGore v. Wrigglesworth, 114 F.3d 601, 607- 08 (6th Cir. 1997); 42 U.S.C. § 1997e(c). Abrams’s submission is evaluated under a more lenient standard because he is not represented by an attorney. See Erickson v. Pardus, 551 U.S. 89, 94 (2007); Burton v. Jones, 321 F.3d 569, 573 (6th Cir. 2003). At this stage, the Court accepts the plaintiff’s factual allegations as true, and his legal claims are liberally construed in his favor. See Bell Atlantic Corp. v. Twombly, 550 U.S. 544, 555-56 (2007). Abrams names the following defendants in his amended complaint: (1) Warden David Paul; (2) Assistant Warden J. Sizemore; (3) Ms. S. Mattingly; (4) Dr. Rosa Myriam Melendez

(FMC Medical Director); (5) CO Warbash; (6) CO Vago; (7) “RH and NHh of Mid-Atlantic Regional BOP”; and (8) Swanson Security Agency. Abrams asserts claims of retaliation in violation of the First Amendment; cruel and unusual punishment and deliberate indifference to serious medical needs in violation of the Eighth Amendment; and deprivation of due process and equal protection under the Fifth and Fourteenth Amendments. For relief, Abrams seeks monetary damages and an injunction releasing him to home confinement. Several of Abrams’s claims will be dismissed. As the Court previously explained, it cannot direct the Bureau of Prisons to place Abrams in home confinement. [See R. 7 at 2]. To the extent Abrams seeks money damages for alleged violations of his constitutional rights, these claims must be pursued (if at all) under the doctrine announced in Bivens v. Six Unknown Federal Narcotics

Agents, 403 U.S. 388 (1971). Bivens held that an individual may “recover money damages for any injuries . . . suffered as a result of [federal] agents’ violation of” his constitutional rights. Bivens, 403 U.S. at 397. However, the Bivens remedy is judicially created and may be implied only in limited circumstances. Ziglar v. Abbasi, 582 U.S. 120, 130 (2017). Since Bivens was decided in 1971, the Supreme Court has found an implied damages action to be available in the following three circumstances: (1) where federal officials searched a private residence without probable cause in violation of the Fourth Amendment, Bivens, 403 U.S. at 397; (2) where a Congressperson terminated an employee on the basis of gender in violation of the Fifth Amendment, Davis v. Passman, 442 U.S. 228, 249 (1979); and (3) where prison officials displayed deliberate indifference to a prisoner’s serious medical needs in violation of the Eighth Amendment, Carlson v. Green, 446 U.S. 14, 24 (1980). See Ziglar, 582 U.S. at 130-31. Abrams alleges that Warden Paul violated his rights under the First, Eighth, and Fourteenth Amendments by denying his motion for compassionate release “with deliberate indifference and

intimidation, retaliation and machination.” But the Warden’s denial of Abrams’s compassionate release motion does not give rise to a constitutional violation. See Greenholz v. Inmates of Nebraska Penal & Corr. Complex, 442 U.S. 1, 7 (1979) (“There is no constitutional or inherent right of a convicted person to be conditionally released before the expiration of a valid sentence.”); Hernandez-Castillo v. Bureau of Prison, 56 F. App’x 256, 256-57 (6th Cir. Feb. 20, 2003) (noting that a prisoner has no procedural due process liberty interest in compassionate release). Abrams does not allege any facts indicating that Warden Paul acted with deliberate indifference or otherwise violated Abrams’s constitutional rights. The Court also notes that Abrams filed a motion for compassionate release with his sentencing court, which was denied. United States v. Abrams, 3:22-cv-00190 (M.D. Penn., Sept. 9, 2025). Abrams recently appealed that decision to the United

States Court of Appeals for the Third Circuit. Assistant Warden Sizemore also will be dismissed as a defendant because Abrams’s amended complaint does not include any allegations involving him. See Ashcroft v. Iqbal, 556 U.S. 662, 676 (2009) (“Because vicarious liability is inapplicable to Bivens and § 1983 suits, a plaintiff must plead that each Government-official defendant, through the official’s own individual actions, has violated the Constitution.”). See also In re Refrigerant Compressors Antitrust Litigation, 731 F.3d 586, 589 (6th Cir. 2013) (“An amended complaint supersedes an earlier complaint for all purposes.”). Abrams’s claims against RH and NHh also will be dismissed. Abrams alleges that these “BOP Mid-Atlantic” employees made administrative remedies unavailable by refusing to characterize his grievances as sensitive. However, inmates do not have an “inherent constitutional right to an effective prison grievance procedure.” Davidson v. Federal Bureau of Prisons, 2017

WL 8997005 (6th Cir. Nov. 29, 2017) (quoting Argue v. Hofmeyer, 80 F. App’x 427 430 (6th Cir. 2003)). Abrams also alleges that these defendants violated his rights under the Health Insurance Portability and Accountability Act (“HIPAA”). However, this claim necessarily fails because HIPAA does not provide a private right of action. See Faber v. Ciox Health, LLC, 944 F.3d 593, 596 (6th Cir. 2019). The Court also will dismiss Abrams’s claims against CO Warbash and S. Mattingly.

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Related

Davis v. Passman
442 U.S. 228 (Supreme Court, 1979)
Carlson v. Green
446 U.S. 14 (Supreme Court, 1980)
Erickson v. Pardus
551 U.S. 89 (Supreme Court, 2007)
Bell Atlantic Corp. v. Twombly
550 U.S. 544 (Supreme Court, 2007)
Ashcroft v. Iqbal
556 U.S. 662 (Supreme Court, 2009)
Ronnie Burton v. Wendee Jones
321 F.3d 569 (Sixth Circuit, 2003)
Ziglar v. Abbasi
582 U.S. 120 (Supreme Court, 2017)
Richard Faber v. Ciox Health, LLC
944 F.3d 593 (Sixth Circuit, 2019)
Egbert v. Boule
596 U.S. 482 (Supreme Court, 2022)
Hernandez-Castillo v. Bureau of Prisons
56 F. App'x 256 (Sixth Circuit, 2003)
Argue v. Hofmeyer
80 F. App'x 427 (Sixth Circuit, 2003)

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James P. Abrams v. David Paul, Warden, et al., Counsel Stack Legal Research, https://law.counselstack.com/opinion/james-p-abrams-v-david-paul-warden-et-al-kyed-2025.