Karl C. Mitchell v. Superintendent

CourtDistrict Court, E.D. Virginia
DecidedFebruary 4, 2026
Docket1:25-cv-01191
StatusUnknown

This text of Karl C. Mitchell v. Superintendent (Karl C. Mitchell v. Superintendent) is published on Counsel Stack Legal Research, covering District Court, E.D. Virginia primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Karl C. Mitchell v. Superintendent, (E.D. Va. 2026).

Opinion

IN THE UNITED STATES DISTRICT COURT FOR THE EASTERN DISTRICT OF VIRGINIA Alexandria Division

KARL C. MITCHELL, ) Plaintiff, ) ) v. ) No. 1:25-cv-1191 (RDA/WPB) ) SUPERINTENDENT, ) Defendant. )

MEMORANDUM OPINION AND ORDER

Karl C. Mitchell, a Virginia inmate, has filed a pro se complaint pursuant to 42 U.S.C. § 1983 alleging that his constitutional rights were violated because he did not receive a tablet for several months while detained within the Rappahannock Regional Jail (“RRJ”), Stafford, Virginia. Dkt. No. 1. Without seeking leave to amend, Plaintiff filled an amended complaint on August 7, 2025, alleging again that he was denied use of a tablet while detained in RRJ from April 11, 2025, through July 30, 2025. Dkt. No. 7. Plaintiff alleged that denying him a tablet was discriminatory and prohibited him from free association and free exercise of his religion, “discriminated against [him],” and burdened his ability to exercise his religion. Id. at 2. He was granted leave to proceed in forma pauperis on November 4, 2025, and he filed a motion for leave to file a second amended complaint (“SAC”) on November 21, 2025. Dkt. No. 12. Because Plaintiff is a prisoner, however, the Court must screen his complaint to determine whether it is frivolous, malicious, or fails to state any claims upon which relief may be granted. See 28 U.S.C. § 1915A.1

1 Section 1915A provides: (a) Screening.—The court shall review, before docketing, if feasible or, in any event, as soon as practicable after docketing, a complaint in a civil action in which a prisoner seeks redress from a governmental entity or officer or employee of a governmental entity. (b) Grounds for dismissal.—On review, the court shall identify cognizable claims or dismiss the complaint, or any portion of the complaint, if the complaint— I. FACTUAL BACKGROUND Plaintiff alleges that tablets are assigned to inmates at RRJ and “are the primary means for inmates to receive mail and visits from private parties”; “are the primary means for inmates to receive religious, educational, and rehabilitative material such as books, study guides, sermons,

counseling, and music”; and “are the primary means for inmates to receive other entertainment material such as games and secular music”; however, “not all inmates immediately get” a tablet, and RRJ’s “policy or custom” for issuing tablets is “patently discriminatory.” The tablets are issued at the jailer’s discretion. Plaintiff alleges there is no rational, compelling or penological basis for this policy and it results in discrimination. Dkt. No. 12-1 at 1-2. Plaintiff alleges he was discriminated against from April 11, 2025, through July 30, 2025, because he was not issued a tablet and that numerous inmates, processed after him, were given tablets. Plaintiff’s ability to exercise his religion (Christianity) was substantially burdened because without a tablet he “couldn’t receive spiritual enrichment from the spiritual music and related material.” Without a tablet, Plaintiff “couldn’t associate with any family or friends through the

mail or receive visits from them on the tablet.” Id. at 2. In the SAC, Plaintiff claims that the “facially discrim[inatory] polices or customs” at RRJ “for issuing tablets” (A) prohibited him from association and free exercise of his religion; (B) subjected him to cruel and unusual punishment; (C) discriminated against him; and (D) substantially burdened his religion.

(1) is frivolous, malicious, or fails to state a claim upon which relief can be granted; or (2) seeks monetary relief from a defendant who is immune from such relief. II. LEAVE TO AMEND “Under Fed. R. Civ. P. 15(a), leave to amend a pleading ‘shall be freely given when justice so requires.’ . . . [And] leave to amend a pleading should be denied only when the amendment would be prejudicial to the opposing party, there has been bad faith on the part of the moving party,

or the amendment would be futile.” Johnson v. Oroweat Foods Co., 785 F.2d 503, 509 (4th Cir. 1986) (citations omitted). As the SAC has not yet been screened, and there is no prejudice or bad faith evident, leave to amend will be granted. III. STANDARD OF REVIEW In reviewing a complaint pursuant to § 1915A, a district court applies the same standard as when evaluating a Rule 12(b)(6) motion. To survive such a motion, “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 Atlantic Corp. v. Twombly, 550 U.S. 544, 570 (2007)). A claim is facially plausible if “the factual content of a complaint allows the court to draw the reasonable inference that the defendant is liable for the misconduct alleged.”

Nemet Chevrolet, Ltd. v. Consumeraffairs.com, Inc., 591 F.3d 250, 256 (4th Cir. 2009) (citation omitted). A complaint must therefore allege facts in support of each element of each claim the plaintiff raises; “threadbare recitals of the elements of a cause of action, supported by mere conclusory statements,” are insufficient. Iqbal, 556 U.S. at 678. While a court must construe a pro se complaint liberally, a court “is not bound by the complaint’s legal conclusions,” conclusory allegations, or unwarranted inferences. Robinson v. Am. Honda Motor Co., 551 F.3d 218, 222 (4th Cir. 2009). Additionally, a complaint must be a coherent, comprehensible, and intelligible document. See Jennings v. Emry, 910 F.2d 1434, 1436 (7th Cir. 1990) (a pleading must be presented “with clarity sufficient to avoid requiring a district court or opposing party to forever sift through its pages in search” of the pleader’s claims “without untoward effort”). Rule 8(a)(2) of Federal Rule of Civil Procedure requires “a short and plain statement of the claim showing that the pleader is entitled to relief,” and Rule 8(e)(1) requires that each averment of a pleading be “simple, concise,

and direct.” A court may dismiss a complaint that is “so confused, ambiguous, vague or otherwise unintelligible that its true substance, if any, is well disguised.” Salahuddin v. Cuomo, 861 F.2d 40, 42 (2d Cir. 1988). This is particularly so because a defendant must be able to determine what claim or claims a plaintiff is attempting to raise against him. A complaint must “give the defendant fair notice of what the plaintiff’s claim is and the grounds upon which it rests.” Conley v. Gibson, 355 U.S. 41, 47 (1957). IV. ANALYSIS Applying this standard, the Court will address each of the various legal principles and claims implicated by the SAC. For the following reasons, the Court finds that the SAC lacks the specificity required under Iqbal and Twombly and is also improperly vague in contravention of

Rule 8. Accordingly, the Court will dismiss the SAC without prejudice. A. Personal Involvement As an initial matter, the SAC lists the “Superintendent of RRJ, et al.” but does not attribute any act or omission to the Superintendent or identify any other defendant.

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