Keith v. Summers

CourtDistrict Court, D. South Dakota
DecidedJanuary 21, 2025
Docket4:24-cv-04077
StatusUnknown

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

Bluebook
Keith v. Summers, (D.S.D. 2025).

Opinion

UNITED STATES DISTRICT COURT DISTRICT OF SOUTH DAKOTA SOUTHERN DIVISION

SCOTT DEAN KEITH, 4:24-CV-04077-LLP Plaintiff, ORDER DENYING PLAINTIFF’S Vs. | MOTIONS FOR LEAVE TO PROCEED IN FORMA PAUPERIS, MOTIONS TO SUMMERS, Public Def/Private, South Dakota, | APPOINT COUNSEL, AND MOTION FOR in individual and official capacity; SMITH, HEARING, NOTICE OF RULE 4(m), AND Director Public Defenders Minnehaha County, 1915A SCREENING in individual and official capacity; DECASTRO, Private Firm, in individual and official capacity; MILLER, Paralegal and Public Advocate, in individual and official capacity; MEDICAL MGMT, Medical Provide at Minnehaha County Jail, in individual and official capacity; T. WELBIG, Provide at Medical Mgmt/County Jail, in individual and official capacity; MED. □ JAIL BOARD, The Members of INC at Minnehaha TAI, in individual and official capacity; and ANGEL, Defendants. .

Plaintiff, Scott Dean Keith, an inmate at the Minnehaha County Jail at the start of the lawsuit, filed a pro se civil rights lawsuit under 42 U.S.C. § 1983. Doc. 1. On May 30, 2024, Keith filed an amended complaint. Doc. 9. He also has filed four motions for leave to proceed in forma pauperis, Docs. 2, 6, 10, and 15, but Keith paid the full filing fee before this Court ruled on his motions for leave to proceed in forma pauperis. He filed two motions to appoint counsel, Docs. 12 and 14, and a motion for a hearing, Doc. 16.

I. Motions for Leave to Proceed In Forma Pauperis Keith filed four motions for leave to proceed in forma pauperis and three prisoner trust account reports. Docs. 2, 3, 6, 10, 11, 15, 18. He paid the full filing fee before this Court ruled on his motions for leave to proceed in forma pauperis. Thus, Keith’s motions for leave to proceed in forma pauperis, Docs. 2, 6, 10, and 15, are denied as moot.! See Richmond v. State, 4:24-CV- 04067-ECS, 2024 WL 3385524, at *1 (D.S.D. July 11, 2024). Il. 1915A Screening A. Screening Standard At the time Keith filed his complaint, he was an inmate at the Minnehaha County Jail, in Sioux Falls, South Dakota. Doc. 1 at 1. Before this Court screened Keith’s complaint, he appears to have been released from the jail, then jailed again, and then transferred to the South Dakota Human Services Center. Docs. 8, 13, 17. Under 28 U.S.C. § 1915A(a), “[t]he court shall review ...a complaint in a civil action in which a prisoner seeks redress from a governmental entity or officer or employee of a governmental entity.” A “prisoner” is defined as “any person incarcerated or detained in any facility who is accused of, convicted of sentenced for, or adjudicated delinquent for, violations of criminal law or the terms and conditions of parole, probation, pretrial release, or diversionary program.” 28 U.S.C. § 1915A(c). A plaintiff's prisoner status is determined at the time when he filed the action. See Williams v. Scalleta, 11 F. App’x 677, 678 (8th Cir. 2001) (per curiam) (holding that 28 U.S.C. § 1915, which uses the same definition of “prisoner” as § 1915A(c), considers an individual’s status at the time the civil

' Keith alleges that he believes that in one of his prisoner trust accounts the average monthly balance has been falsified and was incorrect, but he has not alleged any claims, sued who he believes was responsible, submitted any evidence, or alleged any real injury. See Doc. 17 at 1.

action is filed); Olivas v. Nev. ex rel. Dep’t of Corr., 856 F.3d 1281, 1284 (9th Cir. 2017) (per curiam) (“a court may screen a complaint pursuant to 28 U.S.C. § 1915A only if, at the time the plaintiff files the complaint,” he meets the definition of “prisoner”); Flavor v. Holt, 2024 U.S. Dist. LEXIS 227242, at *1 (M.D. Ga. June 28, 2024) (“Although Plaintiff was no longer incarcerated at the time he filed the amended pleading in this action, screening of the Amended Complaint pursuant to 28 U.S.C. § 1915A is still appropriate because Plaintiff was incarcerated at the time he filed this action with his original complaint.”), R&R adopted in 2024 US. Dist. LEXIS 226546 (M.D. Ga. July 29, 2024). Thus, Keith is considered a prisoner for § 1915A purposes. Section 1915A only permits a court to screen a prisoner’s complaint if “a prisoner seeks redress from a governmental entity or officer or employee of a governmental entity.” 28 U.S.C. § 1915A(a). Keith sues an employee of a private law firm, employees of a public defender’s office and a public advocates’ office, and contractors with the Minnehaha County Jail. Doc. 9 at 2-3. He also sues the “Med. Jail Board” as “the members of INC at Minnehaha Jai[l,]” id. at 3 (capitalization in original omitted), but it is unclear if Keith is alleging that the Med. Jail Board is part of the Minnehaha County Jail or a separate private entity. Regardless, courts have held that suing public defenders as well as contractors of a department of corrections to provide medical services in a prison was considered government entities or officers for § 1915A purposes. Hutchinson v. Wexford Health Servs., 638 F. App’x 930, 932 (11th Cir. 2016) (per curiam) (holding that claims against contractors of a department of corrections could be screened under § 1915A); Trusty v. Centurion Health Servs., 2020 WL 548225, at *1 (6th Cir. Jan. 7, 2020) (same). See also Blevins v. Lacross, 2022 WL 18135315, at *1-2 (W.D. Wash. Dec. 5, 2022) (screening a complaint under § 1915A and recommending dismissal of complaint when sole

defendant was a public defender), R&R adopted by 2023 WL 112042 (W.D. Wash. Jan. 5, 2023); Vaughn v. Buchanon, 2024 WL 1867184, at *1—2 (W.D. Ark. Apr. 1, 2024) (same), RER adopted by 2024 WL 1863113 (W.D. Ark. Apr. 29, 2024); Parker v. Va. Beach Pub. Defs. Off, 2011 WL 8332971, at *1—2 (E.D. Va. Sept. 20, 2011) (screening and dismissing a complaint under § 1915A when the sole defendant was a public defender). Thus, Keith has sufficiently sued governmental entities or officers or employees of a government entity such that this Court shall screen Keith’s claims under § 1915A. See Ehlers v. U.S. Navy, 2016 U.S. Dist. LEXIS 51753, at *7 (D. Minn. Mar. 14, 2016) (holding that even if some defendants are not government actors, “Tujnder § 1915A(a), the screening requirement is triggered when a prisoner seeks redress from a governmental defendant. Section 1915A(b) is clear that, once this screening requirement is triggered under § 1915A(a), the court’s review must encompass the entire complaint, including any portions of the complaint that would not have been subject to screening if not filed alongside the claims that triggered screening.”), R&R adopted by 2016 U.S. Dist. LEXIS 51456 (D. Minn. Apr. 18, 2016). B. Amended Complaint “A party may amend its pleading once as a matter of course no later than . . . 21 days after serving it[.]” Fed. R. Civ. P. 15(a)(1)(A). Because Keith filed his amended complaint before his complaint was served on Defendants, see Doc. 9, he could amend his complaint as a matter of course.

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Keith v. Summers, Counsel Stack Legal Research, https://law.counselstack.com/opinion/keith-v-summers-sdd-2025.