Lamb v. Garland County Detention Center

CourtDistrict Court, W.D. Arkansas
DecidedJune 30, 2025
Docket6:24-cv-06134
StatusUnknown

This text of Lamb v. Garland County Detention Center (Lamb v. Garland County Detention Center) is published on Counsel Stack Legal Research, covering District Court, W.D. Arkansas primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Lamb v. Garland County Detention Center, (W.D. Ark. 2025).

Opinion

IN THE UNITED STATES DISTRICT COURT WESTERN DISTRICT OF ARKANSAS HOT SPRINGS DIVISION

BLAZE CONNOR LAMB PLAINTIFF

v. Case No. 6:24-cv-6134

GARLAND COUNTY DETENTION CENTER; SUSAN BRAINSETTER (Deputy); B. CANNON (Deputy); INMATE JORDAN WARD; INMATE PAYTON WICKLAND; NURSE KAYLA; NURSE JASON; NURSE STANFORD; DEPUTY SGT. ARBURY; DEPUTY ANGEL; DEPUTY TRENT; INMATE JILLIAN; and INMATE VERONICA DEFENDANTS

ORDER

Before the Court is a Report and Recommendation (“R&R”) issued by the Honorable Mark E. Ford, United States Magistrate Judge for the Western District of Arkansas. ECF No. 29. Upon preservice screening of Plaintiff’s Amended Complaint (ECF No. 10) pursuant to 28 U.S.C. § 1915A(a), Judge Ford recommends that: 1) The Garland County Detention Center be terminated as a Defendant in this case. 2) Plaintiff’s claims against Inmate Defendants Jillian, Veronica, Wickland, and Ward be dismissed without prejudice, and that these Defendants be terminated from this case. 3) Plaintiff’s claims for teasing, taunting, and verbal threats be dismissed without prejudice. 4) Plaintiff’s claims for defamation be dismissed without prejudice. 5) Plaintiff’s claim alleging that his criminal conviction was unconstitutionally obtained be dismissed without prejudice. 6) Plaintiff’s failure to protect claim against Defendants Cannon, Jason, Angel, Brainsetter, Trent, Arbury, and Kayla regarding the alleged sexual assault by an unnamed Garland County lieutenant remain for service and further review. 7) Plaintiff’s conditions of confinement claim against Defendants Cannon, Brainsetter, Stanford, Arbury, Angel, Kayla, and Jason that they put drugs and/or poison in his food remain for service and further review.

8) Plaintiff’s denial of medical care claim against Defendants Kayla and Jason for denial of medical care after the alleged sexual assault remain for service and further review. Plaintiff filed timely objections. ECF No. 30. The Court finds the matter ripe for consideration. I. LEGAL STANDARD The Court may designate a magistrate judge to hear pre- and post-trial matters and to submit to the Court proposed findings of fact and recommendations for disposition. 28 U.S.C. § 636(b)(1). Within fourteen days of receipt of a magistrate judge’s report and recommendation, “a party may serve and file specific written objections to the proposed findings and recommendations.” Fed. R. Civ. P. 72(b)(2); accord Local Rule 72.2(VII)(C). After conducting an appropriate review of the report and recommendation, the Court may then “accept, reject, or

modify, in whole or in part, the findings or recommendations made by the magistrate judge . . . or recommit the matter to the magistrate judge with instructions.” 28 U.S.C. § 636(b)(1). “[T]he specific standard of review depends, in the first instance, upon whether or not a party has objected to portions of the report and recommendation.” Anderson v. Evangelical Lutheran Good Samaritan Soc’y, 308 F. Supp. 3d 1011, 1015 (N.D. Iowa 2018). Generally, “objections must be timely and specific” to trigger de novo review. Thompson v. Nix, 897 F.2d 356, 358-59 (8th Cir. 1990). However, the Court may, in its discretion, conduct a de novo review of any issue in a report and recommendation. Thomas v. Arn, 474 U.S. 140, 154 (1985). The Court must apply a liberal construction when determining whether pro se objections are specific. Hudson v. Gammon, 46 F.3d 785, 786 (8th Cir. 1995). The Court must dismiss a complaint, or any portion of it, if it contains claims that are frivolous, malicious, or fail to state a claim upon which relief may be granted. 28 U.S.C. § 1915A(b). A claim is frivolous if “it lacks an arguable basis either in law or in fact.” Neitzke v.

Williams, 490 U.S. 319, 325 (1989). A claim fails to state a claim upon which relief may be granted if it does not allege “enough facts to state a claim to relief that is plausible on its face.” Bell Atl. Corp. v. Twombly, 550 U.S. 544, 570 (2007). II. DISCUSSION Plaintiff objects to two aspects of the R&R. The Court finds these objections sufficiently specific to require a de novo review of the challenged recommendations. A. Claims against Inmate Defendants Plaintiff names Inmate Defendants Payton Wickland and Jordan Ward in Claim Three and Claim Five, both brought pursuant to § 1983. ECF No. 14, pp. 9-10, 14-15. In Claim Three, Plaintiff alleges that Defendant Wickland and Ward attempted to kill him while he was detained

in the Garland County Detention Center (“GCDC”). In Claim Five, Plaintiff generally alleges that he was coerced into signing a plea agreement but does not mention any actions by Defendants Wickland or Ward. Judge Ford recommends that all claims against all Inmate Defendants be dismissed without prejudice. ECF No. 29, p. 7. Judge Ford explains that Plaintiff makes no allegations against Inmates Jillian and Veronica and simply lists them as Defendants, and that Plaintiff failed to allege that Inmates Wickland and Jordan were acting jointly with any State official or their agents. Plaintiff’s objection argues that no Inmate Defendant should be dismissed because he clearly stated that these Defendants were working in concert with GCDC staff to kill him. ECF No. 30, p. 1. The Court finds that Claim Three against Defendants Wickland and Ward should remain, and that Defendants Jillian and Veronica should be terminated from this case. A § 1983 claim against a private actor is only viable if a plaintiff can show that the private party “is a willful participant in joint action with the State or its agents” and that “there was a mutual understanding,

or a meeting of the minds, between the private party and a state actor.” Hamilton v. City of Hayti, Mo., 948 F.3d 921, 930 (8th Cir. 2020) (quotations omitted). In Claim Three, Plaintiff asserts that Defendants Wickland and Ward had “help from deputies” and that these Defendants had “a promise of payment and bond from deputies” if they successfully killed Plaintiff. ECF No. 14, p. 10. Liberally construing Plaintiff’s claim, the Court finds these allegations as sufficiently stating that Defendants Wickland and Ward were collaborating with GCDC staff and make them susceptible to § 1983 claims. See Hamilton, 948 F.3d at 930. However, Plaintiff makes no specific allegations against Wickland and Ward in Claim Five, and Defendants Jillian and Veronica are merely included in a list of Defendants. Simply listing Defendants without making factual allegations is insufficient to state a claim against them. See Krych v. Hass, 83 F. App’x 854, 855

(8th Cir. 2003). Accordingly, Claim Three against Defendants Wickland and Ward shall proceed, and Defendants Veronica and Jillian will be terminated from this matter entirely. Claim Five will be dismissed entirely for the reasons explained below. B.

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Related

Thomas v. Arn
474 U.S. 140 (Supreme Court, 1986)
Neitzke v. Williams
490 U.S. 319 (Supreme Court, 1989)
Bell Atlantic Corp. v. Twombly
550 U.S. 544 (Supreme Court, 2007)
John Hudson v. Tony Gammon
46 F.3d 785 (Eighth Circuit, 1995)
Chris R. Krych v. Sheryl Ramstad Hvass
83 F. App'x 854 (Eighth Circuit, 2003)
Henry Hamilton v. City of Hayti, Missouri
948 F.3d 921 (Eighth Circuit, 2020)
Marcus Mitchell v. Kyle Kirchmeier
28 F.4th 888 (Eighth Circuit, 2022)
Anderson v. Evangelical Lutheran Good Samaritan Soc'y
308 F. Supp. 3d 1011 (N.D. Iowa, 2018)
Thompson v. Nix
897 F.2d 356 (Eighth Circuit, 1990)

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Lamb v. Garland County Detention Center, Counsel Stack Legal Research, https://law.counselstack.com/opinion/lamb-v-garland-county-detention-center-arwd-2025.