Jenna Hattaway, as Surviving Spouse of Desmond Layne Hattaway, and as Personal Representative of the Estate of Desmond Layne Hattaway, Deceased v. Georgia Department of Corrections, et al.

District Court, M.D. Georgia·Decided August 17, 2026·No. 5:25-cv-00018·Unknown

Opinion

IN THE UNITED STATES DISTRICT COURT FOR THE MIDDLE DISTRICT OF GEORGIA MACON DIVISION

JENNA HATTAWAY, as Surviving : Spouse of Desmond Layne Hattaway, : and as Personal Representative of the : Estate of Desmond Layne Hattaway, : Deceased, : : Plaintiff, : : v. : Case No.: 5:25-cv-18-CAR : GEORGIA DEPARTMENT OF : CORRECTIONS, et al., : : Defendants. : :

ORDER ON MOTION TO DISMISS AND CONSTRUED MOTION TO AMEND

After suffering a mental health crisis, Desmond Layne Hattaway (“Decedent”) hung himself with a pair of pants and died in a mental health observation cell at the Georgia Diagnostic & Classification Prison (“GDCP”). Plaintiff Jenna Hattaway, as Decedent’s surviving spouse and the administrator of his estate, first filed a lawsuit against the Georgia Department of Corrections (“GDC”) and nine GDC officers, alleging they violated the Eighth Amendment and caused Decedent’s death by failing to carry out a mental health order restricting Decedent’s clothing to a suicide smock and placing him under observation.1 Plaintiff later filed a second lawsuit against Defendant Centurion of

1 Doc. 1-1 at 5-19 (hereinafter “GDC Complaint”). Georgia, LLC, the entity that provided mental health services for GDC, and its employee or agent, Defendant Angela Boatwright (the “Centurion Defendants”), alleging mental

health staff violated the Eighth Amendment and caused Decedent’s death by failing to fully communicate the mental health order to prison security staff.2 The Court consolidated the two wrongful death actions.3 Plaintiff then filed—without first

requesting the Court’s leave—a “Recast Complaint” consolidating both actions’ claims and factual allegations.4 Subsequently, the Centurion Defendants filed their Motion to Dismiss Plaintiff’s wrongful death claims because they are barred by the statute of

limitations and all § 1983 claims because Plaintiff fails to state a claim.5 The Court CONSTRUES Plaintiff’s “Recast Complaint” [Doc. 18] as a Motion for Leave to File a Consolidated Amended Complaint.6 For the reasons explained below, Plaintiff’s Construed Motion to Amend [Doc. 18] is DENIED, Plaintiff’s Motion

requesting a hearing [Doc. 38] is DENIED as unnecessary; and the Centurion Defendants’ Motion to Dismiss [Doc. 19] is GRANTED. Thus, the following claims against Defendant Boatwright are DISMISSED: (a) Plaintiff’s claims brought in her

capacity as Decedent’s surviving spouse for (1) wrongful death under O.C.G.A. § 51–4– 2(a), (2) wrongful death under 42 U.S.C. § 1983, and (3) attorney’s fees under 42 U.S.C. §

2 Hattaway v. Centurion of Georgia LLC, Case No. 5:25-cv-448-CAR, Doc. 1 (hereinafter “Centurion Complaint”). 3 Doc. 17. 4 Doc. 18. 5 Doc. 19. 6 Doc. 18. 1988; and (b) Plaintiff’s claims brought under federal law in her capacity as the administrator of Decedent’s estate for (1) survival damages of (i) pre-death pain and

suffering and (ii) funeral and other necessary expenses under § 1983, and (2) attorney’s fees under § 1988. The following claims brought under state law in Plaintiff’s capacity as the administrator of Decedent’s estate are going forward: (a) Plaintiff’s direct claims

against Defendant Boatwright for (1) medical malpractice, (2) pre-death pain and suffering, (3) funeral and other necessary expenses, and (4) punitive damages; and (b) Plaintiff’s vicarious liability claims against Defendant Centurion for the remaining state-

law claims against Defendant Boatwright.7 The Court hereby LIFTS the stay of discovery [Doc. 24] entered in this consolidated action and DIRECTS the Parties to file a proposed scheduling and discovery order for this consolidated action in accordance with the Court’s form within

7 Although the Court has dismissed Plaintiff’s federal claims that created the Court’s original jurisdiction, the Court will continue to exercise supplemental jurisdiction over Plaintiff’s remaining state law claims against the Centurion Defendants in this consolidated action. “A district court . . . has the discretion to continue to exercise [supplemental] jurisdiction over state law claims in a case even after dismissing the federal claim that created the original jurisdiction.” Pintando v. Miami-Dade Hous. Agency, 501 F.3d 1241, 1242–43 (11th Cir. 2007) (per curiam) (citing Palmer v. Hosp. Auth., 22 F.3d 1559, 1568 (11th Cir. 1994)). In deciding whether to exercise supplemental jurisdiction, “a district court should consider factors such as ‘judicial economy, convenience, fairness to the parties, and whether all the claims would be expected to be tried together[.]’” Bravo v. Loor-Tuarez, 727 F. App'x 572, 577 (11th Cir. 2018) (quoting Palmer, 22 F.3d at 1569). All factors weigh in favor of retaining jurisdiction in this consolidated action. Plaintiff’s claims for wrongful death and survival damages against the GDC Defendants and her remaining claims for medical malpractice and survival damages against the Centurion Defendants involve common facts (concerning the events preceding Decedent’s death) and can be tried together, thereby conserving judicial resources and promoting convenience. Moreover, Plaintiff’s remaining claims for medical malpractice and survival damages against the Centurion Defendants do not raise any novel or complex issue of state law, and fairness concerns appear neutral. Thus, the Court will continue to exercise supplemental jurisdiction over Plaintiff’s remaining state law claims in the Centurion Complaint. 21 days of this Order’s date. PROCEDURAL HISTORY

On April 16, 2023, Decedent hung himself with a pair of pants and died in a mental health observation cell at the GDCP in Jackson, Georgia. Six months later, on October 16, 2023, Plaintiff was appointed as the administrator of Decedent’s estate.

On December 3, 2024, Plaintiff, as Decedent’s surviving spouse and the administrator of his estate, filed suit in the Superior Court of Butts County against the GDC and nine GDC officers in their individual capacities for wrongful death, asserting

claims for (1) Eighth Amendment deliberate-indifference against the GDC officers under 42 U.S.C. § 1983 and (2) negligence against the GDC under the Georgia Tort Claims Act (“GDC Complaint”).8 On January 13, 2025, the GDC Defendants removed the action— Case No. 5:25-cv-18-CAR—to this Court.9

On October 14, 2025, Plaintiff, as Decedent’s surviving spouse and the administrator of his estate, filed a second suit against the Centurion Defendants in this Court—Case No. 5:25-cv-448-CAR (“Centurion Complaint”), claiming mental health

staff’s failure to fully communicate a mental health order (restricting Decedent’s clothing to a suicide smock and placing him under observation) to prison security staff breached the standard of care for prison mental health providers, violated the Eighth

8 GDC Complaint. 9 Doc. 1. Amendment’s prohibition against deliberate indifference to a prisoner’s serious medical needs, and caused Decedent’s death.10 Plaintiff asserts state and federal claims against

Defendant Boatwright and contends Defendant Centurion is vicariously liable for all state claims against Defendant Boatwright.11 In her capacity as Decedent’s surviving spouse, Plaintiff asserts the following claims: (1) wrongful death under O.C.G.A. § 51–4–2(a);12 (2)

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Jenna Hattaway, as Surviving Spouse of Desmond Layne Hattaway, and as Personal Representative of the Estate of Desmond Layne Hattaway, Deceased v. Georgia Department of Corrections, et al., (M.D. Ga. 2026).

Jenna Hattaway, as Surviving Spouse of Desmond Layne Hattaway, and as Personal Representative of the Estate of Desmond Layne Hattaway, Deceased v. Georgia Department of Corrections, et al. (Jenna Hattaway, as Surviving Spouse of Desmond Layne Hattaway, and as Personal Representative of the Estate of Desmond Layne Hattaway, Deceased v. Georgia Department of Corrections, et al.) — published by Counsel Stack Legal Research, free access to 12M+ legal documents.

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