Kyle J. Johnson v. John Doe

CourtDistrict Court, D. Delaware
DecidedMay 5, 2026
Docket1:25-cv-01115
StatusUnknown

This text of Kyle J. Johnson v. John Doe (Kyle J. Johnson v. John Doe) is published on Counsel Stack Legal Research, covering District Court, D. Delaware primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Kyle J. Johnson v. John Doe, (D. Del. 2026).

Opinion

IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF DELAWARE

KYLE J. JOHNSON, ) ) Plaintiff, ) ) v. ) C.A. No. 25-1115-JLH-EGT ) JOHN DOE, ) ) Defendants. )

REPORT AND RECOMMENDATION

Plaintiff Kyle J. Johnson, a pretrial detainee at Howard R. Young Correctional Institution, filed this action pursuant to 42 U.S.C. § 1983. (D.I. 2). Plaintiff appears pro se and has been granted leave to proceed in forma pauperis. (D.I. 5). The original Complaint was screened by Judge Hall, who dismissed it for failure to state a claim, but with leave to amend. (D.I. 8). The Court proceeds to screen the Amended Complaint pursuant to 28 U.S.C. § 1915(e)(2)(B) and 1915A(a). For the reasons set forth below, the Court recommends that the Amended Complaint be DISMISSED WITH PREJUDICE. I. BACKGROUND Judge Hall previously set forth the facts of this case in a prior screening order. (D.I. 8 at 1-2). Those facts remain largely unchanged in the Amended Complaint. On June 29, 2025, Plaintiff was playing basketball when another inmate fell on top of him and apparently broke his pelvis. (D.I. 9 at 5). Plaintiff was left unattended on the ground for twenty minutes, “pulled” into a court van (rather than on a stretcher) and taken to Wilmington Hospital in shackles. (Id.). When Plaintiff was released from the hospital, Defendant “pulled” Plaintiff back into the van, allegedly exacerbating the injury. (Id. at 6). In his Amended Complaint, Plaintiff adds that he told Defendant he was shackled and asked Defendant not to pull, requests that Defendant “intentionally ignore[d].” Plaintiff continues to name a single John Doe correctional officer as the only Defendant. (Id. at 3). Plaintiff seeks “a civil suit for [his] injury, pain, suffering [and] misery.” (Id. at 8). II. LEGAL STANDARDS A federal court may properly dismiss an action sua sponte under the screening provisions

of 28 U.S.C. § 1915(e)(2)(B) if “the action is frivolous or malicious, fails to state a claim upon which relief may be granted, or seeks monetary relief from a defendant who is immune from such relief.” Ball v. Famiglio, 726 F.3d 448, 452 (3d Cir. 2013) (quotation marks omitted); see also 28 U.S.C. § 1915(e)(2) (in forma pauperis actions). The Court must accept all factual allegations in a complaint as true and view them in the light most favorable to a pro se plaintiff. See Phillips v. County of Allegheny, 515 F.3d 224, 229 (3d Cir. 2008). Because Plaintiff proceeds pro se, his pleading is liberally construed and his 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). A complaint is not automatically frivolous because it fails to state a claim. See Dooley v.

Wetzel, 957 F.3d. 366, 374 (3d Cir. 2020). Rather, a claim is deemed frivolous only where it relies on an “‘indisputably meritless legal theory’ or a ‘clearly baseless’ or ‘fantastic or delusional’ factual scenario.’” Id. The legal standard for dismissing a complaint for failure to state a claim pursuant to § 1915(e)(2)(B)(ii) is identical to the legal standard used when ruling on Rule 12(b)(6) motions. Tourscher v. McCullough, 184 F.3d 236, 240 (3d Cir. 1999). Before dismissing a complaint or claims for failure to state a claim upon which relief may be granted pursuant to the screening provisions of § 1915, however, the Court must grant Plaintiff leave to amend his complaint unless amendment would be inequitable or futile. See Grayson v. Mayview State Hosp., 293 F.3d 103, 114 (3d Cir. 2002). A well-pleaded complaint must contain more than mere labels and conclusions. See Ashcroft v. Iqbal, 556 U.S. 662 (2009); Bell Ad. Corp. v. Twombly, 550 U.S. 544 (2007). A

plaintiff must plead facts sufficient to show that a claim has substantive plausibility. See Johnson v. City of Shelby, 574 U.S. 10, 12 (2014). A complaint may not be dismissed, however, for imperfect statements of the legal theory supporting the claim asserted. See id. at 11. A court reviewing the sufficiency of a complaint must take three steps: (1) take note of the elements the plaintiff must plead to state a claim; (2) identify allegations that, because they are no more than conclusions, are not entitled to the assumption of truth; and (3) when there are well- pleaded factual allegations, assume their veracity and then determine whether they plausibly give rise to an entitlement to relief. Connelly v. Lane Constr. Corp., 809 F.3d 780, 787 (3d Cir. 2016). Elements are sufficiently alleged when the facts in the complaint “show” entitlement to relief. Iqbal, 556 U.S. at 679 (quoting FED. R. CIV. P. 8(a)(2)). Determining whether a claim is plausible

is a “context-specific task that requires the reviewing court to draw on its judicial experience and common sense.” Id. III. DISCUSSION A. Exhaustion Judge Hall previously dismissed Plaintiff’s claims for failure to exhaust, finding that Plaintiff’s original Complaint affirmatively showed that he had not exhausted his administrative remedies. (D.I. 8 at 2). Plaintiff now alleges that further communications in the grievance process “provided no relief” and that the “process has been exhausted.” (D.I. 9 at 8; see also D.I. 2 at 8 (original Complaint indicating that prison officials had received grievance but would get back to Plaintiff at later date)). In the Court’s view, Plaintiff’s pleading no longer evidences a failure to exhaust. Dismissal of Plaintiff’s Amended Complaint for failure to exhaust is not warranted. B. Deliberate Indifference In his Amended Complaint, Plaintiff continues to assert a deliberate indifference claim against one John Doe correctional officer in connection with certain events surrounding his pelvis

injury. (D.I. 9 at 3 & 5). Deliberate indifference claims brought by pretrial detainees under the Fourteenth Amendment are governed by the same standard as deliberate indifference claims brought by sentenced inmates under the Eighth Amendment. See Goode v. Giorla, 643 F. App’x 127, 129 n.3 (3d Cir. 2016). The deliberate indifference standard is high, requiring more than “allegations of malpractice” or a “disagreement as to the proper medical treatment.” Monmouth Cnty. Corr. Institutional Inmates v. Lanzaro, 834 F.2d 326, 346 (3d Cir. 1987). To demonstrate that a prison official was deliberately indifferent, a plaintiff must plausibly allege that prison officials knew of and “reckless[ly] disregarded a substantial risk of serious harm.” Stuart v. Pierce, 587 F. Supp. 3d 127, 137 (D. Del. 2022) (Restrepo, J. sitting by designation) (alteration in original). “[M]ere negligence” is not enough. Farmer v. Brennan, 511 U.S. 825, 835 (1994).

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Related

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)
Dawn Ball v. Famiglio
726 F.3d 448 (Third Circuit, 2013)
Farmer v. Brennan
511 U.S. 825 (Supreme Court, 1994)
Phillips v. County of Allegheny
515 F.3d 224 (Third Circuit, 2008)
Sandra Connelly v. Lane Construction Corp
809 F.3d 780 (Third Circuit, 2016)
Ronald Goode v. Louis Giorla
643 F. App'x 127 (Third Circuit, 2016)
Casey Dooley v. John Wetzel
957 F.3d 366 (Third Circuit, 2020)

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Kyle J. Johnson v. John Doe, Counsel Stack Legal Research, https://law.counselstack.com/opinion/kyle-j-johnson-v-john-doe-ded-2026.