Lewis v. Bonneville County Jail

CourtDistrict Court, D. Idaho
DecidedOctober 2, 2025
Docket1:25-cv-00405
StatusUnknown

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

Bluebook
Lewis v. Bonneville County Jail, (D. Idaho 2025).

Opinion

UNITED STATES DISTRICT COURT FOR THE DISTRICT OF IDAHO

ADAM ELI LEWIS, Case No. 1:25-cv-00405-AKB Plaintiff, INITIAL REVIEW ORDER BY v. SCREENING JUDGE

BONNEVILLE COUNTY JAIL; K. MEACHAM; COUNTY JAIL MEDICAL PROVIDER; CENTURION MEDICAL; and DR. WILKS,

Defendants.

The Clerk of Court conditionally filed Plaintiff Adam Eli Lewis’s Complaint because of Plaintiff’s status as an inmate and in forma pauperis request. A “conditional filing” means that a plaintiff must obtain authorization from the Court to proceed. Upon screening, the Court must dismiss claims that are frivolous or malicious, fail to state a claim upon which relief may be granted, or seek monetary relief from a defendant who is immune from such relief. 28 U.S.C. §§ 1915(e)(2)(B) and 1915A(b). Having reviewed the record, the Court concludes that the Complaint fails to state a claim upon which relief may be granted and contains frivolous claims. Accordingly, the Court enters the following Order directing Plaintiff to file an amended complaint if he intends to proceed. 1. Standards of Law for Screening Complaints A complaint must contain “a short and plain statement of the claim showing that the pleader is entitled to relief.” Fed. R. Civ. P. 8(a)(2). A complaint fails to state a claim for relief under Rule 8 if the factual assertions in the complaint, taken as true, are insufficient for the reviewing court plausibly “to draw the reasonable inference that the defendant is liable for the misconduct alleged.” Ashcroft v. Iqbal, 556 U.S. 662, 678 (2009). To state an actionable claim, a plaintiff must provide “enough factual matter (taken as true) to suggest” that the defendant committed the unlawful act, meaning that sufficient facts are pled “to raise a reasonable expectation that discovery will reveal evidence of illegal [activity].” Bell

Atl. Corp. v. Twombly, 550 U.S. 544, 556 (2007). “A pleading that offers ‘labels and conclusions’ or ‘a formulaic recitation of the elements of a cause of action will not do.’” Iqbal, 556 US. at 678 (quoting Twombly, 550 U.S. at 555). The Court liberally construes the pleadings to determine whether a case should be dismissed for a failure to plead sufficient facts to support a cognizable legal theory or for the absence of a cognizable legal theory. The critical inquiry is whether a constitutional claim, however inartfully pleaded, has an arguable factual and legal basis. See Jackson v. Arizona, 885 F.2d 639, 640 (9th Cir. 1989) (discussing Federal Rule of Civil Procedure 12(b)(6)), superseded by statute on other grounds as stated in Lopez v. Smith, 203 F.3d 1122, 1130 (9th Cir. 2000).

Moreover, even if a complaint meets the pleading requirements, dismissal under §§ 1915 and 1915A is still appropriate if an affirmative defense, such as untimeliness, is an “obvious bar to securing relief on the face of the complaint.” Washington v. Los Angeles Cnty. Sheriff’s Dep’t, 833 F.3d 1048, 1056 (9th Cir. 2016) (internal quotation marks omitted). 2. Factual Allegations Plaintiff is a prisoner in the custody of the Idaho Department of Correction (“IDOC”), currently incarcerated at the Idaho State Correctional Center. Plaintiff alleges that, from September 2021 to August 2022, while he was being held in the Bonneville County Jail, he received inadequate medical treatment. Specifically, Plaintiff alleges that the medical providers at the jail did not follow Plaintiff’s “established medication” regimen. Additionally, Bonneville County Jail medical provider K. Meacham allegedly told Plaintiff he had AIDS in order to manipulate Plaintiff. Compl., Dkt. 3, at 5–7. Plaintiff also asserts claims of inadequate medical treatment, with respect to talar necrosis in Plaintiff’s right ankle, after he was transferred to prison. Specifically, Plaintiff alleges that, from 2023 to the present, Dr. Wilks, a medical provider with Centurion (the private entity that provides

Idaho inmates with medical treatment under contract with the IDOC), did not prescribe Norco for Plaintiff’s pain. Instead, Wilks prescribed Tylenol 3, which Plaintiff claims is insufficient to treat his pain. Id. at 3–4. Plaintiff sues Wilks and Meacham, as well as the Bonneville County Jail and Centurion. Plaintiff also sues an unidentified county jail medical provider. Compl. at 1. Plaintiff alleges that Defendants have violated his Eighth Amendment right to adequate medical treatment while incarcerated. Id. at 2–6. 3. Discussion Plaintiff has not stated a claim upon which relief may be granted. The Court will, however, grant Plaintiff 28 days to amend the Complaint. Any amended complaint should take into

consideration the following. A. Standards of Law Plaintiff brings his claims under 42 U.S.C. § 1983, the civil rights statute. Compl. at 1. To state a plausible civil rights claim, a plaintiff must allege a violation of rights protected by the Constitution or created by federal statute proximately caused by conduct of a person acting under color of state law. Crumpton v. Gates, 947 F.2d 1418, 1420 (9th Cir. 1991). A defendant causes a constitutional deprivation within the meaning of § 1983 “if he does an affirmative act, participates in another’s affirmative acts, or omits to perform an act which he is legally required to do that causes the deprivation.” Johnson v. Duffy, 588 F.2d 740, 743 (9th Cir. 1978). That is, jail or prison officials and medical providers generally are not liable for damages in their individual capacities under § 1983 unless they personally participated in the alleged constitutional violations. Taylor v. List, 880 F.2d 1040, 1045 (9th Cir. 1989); see also Iqbal, 556 U.S. at 677 (“[E]ach Government official, his or her title notwithstanding, is only liable for his or her own misconduct.”). Section 1983 does not allow for recovery against an employer or principal

simply because an employee or agent committed misconduct. Taylor, 880 F.2d at 1045. To bring a § 1983 claim against a local governmental entity (such as the Bonneville County Jail) or a private entity performing a government function (such as Centurion), a plaintiff must allege that the execution of an official policy or unofficial custom inflicted the injury of which the plaintiff complains, as required by Monell v. Dep’t of Soc. Servs. of New York, 436 U.S. 658, 694 (1978); see also Tsao v. Desert Palace, Inc., 698 F.3d 1128, 1139 (9th Cir. 2012) (applying Monell to private entities performing a government function). Under Monell, the requisite elements of a § 1983 claim against such an entity are the following: (1) the plaintiff was deprived of a constitutional right; (2) the entity had a policy or custom; (3) the policy or custom amounted to

deliberate indifference to plaintiff’s constitutional right; and (4) the policy or custom was the moving force behind the constitutional violation. Mabe v. San Bernardino Cnty., 237 F.3d 1101, 1110–11 (9th Cir. 2001).

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Lewis v. Bonneville County Jail, Counsel Stack Legal Research, https://law.counselstack.com/opinion/lewis-v-bonneville-county-jail-idd-2025.