Lee v. McCracken County Jail

CourtDistrict Court, W.D. Kentucky
DecidedAugust 16, 2024
Docket5:24-cv-00024
StatusUnknown

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

Bluebook
Lee v. McCracken County Jail, (W.D. Ky. 2024).

Opinion

UNITED STATES DISTRICT COURT WESTERN DISTRICT OF KENTUCKY AT PADUCAH

ADAM L. LEE PLAINTIFF

v. CIVIL ACTION NO. 5:24CV-P24-CRS

MCCRACKEN COUNTY JAIL DEFENDANT

MEMORANDUM OPINION Plaintiff Adam L. Lee filed the instant pro se 42 U.S.C. § 1983 action. The amended complaint (DN 9)1 is before the Court on initial review pursuant to 28 U.S.C. § 1915A. For the reasons stated below, the Court will dismiss the action. I. SUMMARY OF COMPLAINT Plaintiff was a pretrial detainee at the McCracken County Jail (MCJ) at the time pertinent to this suit and is now incarcerated at another facility. In the caption of the amended complaint, he lists Defendants as “McCracken County Jail as a whole and the company they lease the medical unit to as a whole.” Plaintiff states that when he entered MCJ he “informed the jail and medical staff about my disability’s and medical problems.” He asserts, “Never once did I see a doctor and the head nurse took it upon herself to change my critical seazur meds and deniy the dietery needs I have as a Type 2 diabetic.” He continues, “In order for any of this to happen I should have had a full medical exam with a real Dr. That never happened I informed everyone of the jail staff members about this and was threatened by the jail and medical staff.” Plaintiff states, “This is a great example of abuse of athurity figure’s position all the way through there chain of command.” He alleges a violation of his constitutional and civil rights and medical negligence. He also states,

1 By prior Order (DN 8), the Court ordered Plaintiff to file an amended complaint on the Court’s approved § 1983 complaint form and directed that the amended complaint would supersede the original complaint. “Im asking the Court for help please look into all the other pending suits against them. Im asking the Court to have an investigation started on both the jail staff and the medical units staff for there action.” He also requests the appointment of counsel “because I have no income and I have a disability and should not be allowed to represent myself.” As relief, he seeks compensatory and punitive damages and an apology letter.

II. LEGAL STANDARD When a prisoner initiates a civil action seeking redress from a governmental entity, officer, or employee, the trial court must review the complaint and dismiss the complaint, or any portion of it, if the court determines that the complaint 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. See § 1915A(b)(1), (2); McGore v. Wrigglesworth, 114 F.3d 601, 604 (6th Cir. 1997), overruled on other grounds by Jones v. Bock, 549 U.S. 199 (2007). In order to survive dismissal for failure to state a claim, “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 Atl. Corp. v. Twombly, 550 U.S. 544, 570 (2007)). “[A] district court must (1) view the complaint in the light most favorable to the plaintiff and (2) take all well-pleaded factual allegations as true.” Tackett v. M & G Polymers, USA, LLC, 561 F.3d 478, 488 (6th Cir. 2009) (citing Gunasekera v. Irwin, 551 F.3d 461, 466 (6th Cir. 2009) (citations omitted)). “But the district court need not accept a ‘bare assertion of legal conclusions.’” Tackett, 561 F.3d at 488 (quoting Columbia Natural Res., Inc. v. Tatum, 58 F.3d 1101, 1109 (6th Cir. 1995)). Although this Court recognizes that pro se pleadings are to be held to a less stringent standard than formal pleadings drafted by lawyers, Haines v. Kerner, 404 U.S. 519, 520-21 (1972); Jourdan v. Jabe, 951 F.2d 108, 110 (6th Cir. 1991), “[o]ur duty to be ‘less stringent’ with pro se complaints does not require us to conjure up unpled allegations.” McDonald v. Hall, 610 F.2d 16, 19 (1st Cir. 1979) (citation omitted). III. ANALYSIS A. § 1983 claims Section 1983 creates a cause of action against any person who, under color of state law,

causes the deprivation of a right secured by the Constitution or the laws of the United States. A claim under § 1983 must therefore allege two elements: (1) the deprivation of federal statutory or constitutional rights by (2) a person acting under color of state law. West v. Atkins, 487 U.S. 42, 48 (1988); Flint v. Ky. Dep’t of Corr., 270 F.3d 340, 351 (6th Cir. 2001). Absent either element, no § 1983 claim exists. Christy v. Randlett, 932 F.2d 502, 504 (6th Cir. 1991). The court will first examine whether the amended complaint states a violation of statutory or constitutional rights. 1. Medical treatment “Pretrial detainees have a right to adequate medical care under the Fourteenth

Amendment. An officer violates that right if that officer shows deliberate indifference to [a pretrial detainee’s] serious medical needs[.]” Hyman v. Lewis, 27 F. 4th 1233, 1237 (6th Cir. 2022) (internal citations and quotation marks omitted; brackets in Hyman).2 The Sixth Circuit has articulated the standard for a Fourteenth Amendment claim of deliberate indifference as requiring that a plaintiff must show (1) the existence of a sufficiently serious medical need, and (2) “that each defendant ‘acted deliberately (not accidentally), [and] also recklessly in the face of an unjustifiably high risk of harm that is either known or so obvious that it should be known.’”

2 Formerly, a pretrial detainee’s right to medical care was analyzed under the same Eighth Amendment standards that apply to claims brought by convicted inmates. However, in Brawner v. Scott Cnty., 14 F.4th 585, 596 (6th Cir. 2021), the standard for a pretrial detainee’s Fourteenth Amendment medical care claim was clarified to require a lesser showing of culpability than for an Eight Amendment claim. Helphenstine v. Lewis Cnty., Ky., 60 F.4th 305, 317 (6th Cir. 2023) (quoting Brawner, 14 F.4th at 596 (6th Cir. 2021)). For the purposes of initial review, the Court concludes that Plaintiff’s need for seizure medication meets the objective requirement for stating a sufficiently serious medical need. However, Plaintiff cannot satisfy the second component because he does not allege that any

personnel acted deliberately or recklessly. A pretrial detainee must allege “more than negligence but less than subjective intent—something akin to reckless disregard.” Brawner, 14 F.4th at 596 (internal quotation marks omitted). Where “a prisoner has received some medical attention and the dispute is over the adequacy of the treatment, federal courts are generally reluctant to second guess medical judgments and to constitutionalize claims which sound in state tort law.” Westlake v.

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Related

Haines v. Kerner
404 U.S. 519 (Supreme Court, 1972)
Diamond v. Charles
476 U.S. 54 (Supreme Court, 1986)
West v. Atkins
487 U.S. 42 (Supreme Court, 1988)
Bell Atlantic Corp. v. Twombly
550 U.S. 544 (Supreme Court, 2007)
Jones v. Bock
549 U.S. 199 (Supreme Court, 2007)
Ashcroft v. Iqbal
556 U.S. 662 (Supreme Court, 2009)
Anthony F. McDonald v. Frank A. Hall
610 F.2d 16 (First Circuit, 1979)
Karen Christy v. James R. Randlett
932 F.2d 502 (Sixth Circuit, 1991)
James M. Jourdan, Jr. v. John Jabe and L. Boyd
951 F.2d 108 (Sixth Circuit, 1991)
Tackett v. M & G POLYMERS, USA, LLC
561 F.3d 478 (Sixth Circuit, 2009)
Gunasekera v. Irwin
551 F.3d 461 (Sixth Circuit, 2009)
Carney v. Craven
40 F. App'x 48 (Sixth Circuit, 2002)

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Lee v. McCracken County Jail, Counsel Stack Legal Research, https://law.counselstack.com/opinion/lee-v-mccracken-county-jail-kywd-2024.