Linkenauger v. Trinity Food Services

CourtDistrict Court, S.D. West Virginia
DecidedFebruary 4, 2020
Docket2:20-cv-00068
StatusUnknown

This text of Linkenauger v. Trinity Food Services (Linkenauger v. Trinity Food Services) is published on Counsel Stack Legal Research, covering District Court, S.D. West Virginia primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Linkenauger v. Trinity Food Services, (S.D.W. Va. 2020).

Opinion

IN THE UNITED STATES DISTRICT COURT FOR THE SOUTHERN DISTRICT OF WEST VIRGINIA

CHARLESTON DIVISION

JOHN STEPHEN LINKENAUGER, II, ) ) Plaintiff, ) v. ) Civil Action No. 2:20-00068 ) WVDCR, et al., ) ) Defendants. )

O R D E R

On January 28, 2020, Plaintiff, acting pro se,1 filed his Complaint in this matter claiming entitlement to relief pursuant to 42 U.S.C. § 1983.2 (Document No. 2.) Specifically, Plaintiff appears to be claiming that Defendants provided inadequate medical care in violation of his Eighth Amendment rights.3 (Id.) Plaintiff names the following as Defendants: (1) Trinity Food

1 Because Plaintiff is acting pro se, the documents which he has filed in this case are held to a less stringent standard than if they were prepared by a lawyer and therefore, they are construed liberally. See Haines v. Kerner, 404 U.S. 519, 520-21, 92 S.Ct. 594, 30 L.Ed.2d 652 (1972). 2 Title 42 U.S.C. § 1983 provides a remedy for violations of all “rights, privileges, or immunities secured by the Constitution and laws [of the United States].” Thus, Section 1983 provides a “broad remedy for violations of federally protected civil rights.” Monell v. Dep’t of Social Services, 436 U.S. 658, 685, 98 S.Ct. 2018, 56 L.Ed.2d 611 (1978). 3 Under the Eighth Amendment, sentenced prisoners are entitled to “adequate food, clothing, shelter, sanitation, medical care and personal safety.” Wolfish v. Levi, 573 F.2d 118, 125 (2d Cir. 1978), rev’d on other grounds, Bell v. Wolfish, 441 U.S. 520, 99 S.Ct. 1861, 60 L.Ed.2d 447 (1979). See also Farmer v. Brennan, 511 U.S. 825, 832, 114 S.Ct. 1970, 1976, 128 L.Ed.2d 811 (1994)(Supreme Court noted that Eighth Amendment imposes certain duties upon prison officials to “ensure that inmates receive adequate food, clothing, shelter and medical care, and must ‘take reasonable measures to guarantee the safety of the inmates.’”), quoting Hudson v. Palmer, 468 U.S. 517, 526 - 27, 104 S.Ct. 3194, 3200, 82 L.Ed.2d 393 (1984)); Rhodes v. Chapman, 452 U.S. 337, 347, 101 S.Ct. 2392, 2399, 69 L.Ed.2d 59 (1981)(Court held that only those conditions depriving inmates of “the minimal civilized measure of life’s necessities” are sufficiently grave to form the basis of an Eighth Amendment violation). Sentenced prisoners are therefore constitutionally guaranteed adequate medical care under the Eighth Amendment. To establish a violation of the Eighth Amendment in the context of a challenge to conditions of confinement, an inmate must allege and prove (1) a “sufficiently serious” deprivation under an objective standard and (2) that prison officials acted with “deliberate indifference” to the inmate’s health and safety under a subjective standard. Wilson v. Seiter, 501 U.S. 294, 297 - 99, 111 S.Ct. 2321, 2323 - 2325, 115 L.Ed.2d 271 (1991). A sufficiently serious deprivation occurs when “a prison official’s act or omission . . . result[s] in the denial of the minimal civilized measure of life’s necessities.’” Id. at 298, 111 S.Ct. 2321 (citing Rhodes v. Chapman, 452 U.S. at 347, 101 S.Ct. 2392).“In order to establish the imposition of cruel and unusual punishment, a prisoner must prove Services, Food and Nutrition Providers at South Central Regional Jail; and (2) WVRJA/WVDCR. (Id.) Generally speaking, to state and prevail upon a claim under 42 U.S.C. § 1983, a Plaintiff must prove that (1) a person acting under color of State law (2) committed an act which deprived him of an alleged right, privilege or immunity protected by the Constitution or laws of the United States. To the extent Plaintiff names the WVRJA/WVDCR as defendants, Plaintiff is NOTIFIED that a Section 1983 claims must be directed at a “person.”4 See Preval v. Reno, 203

F.3d 821 (4th Cir. 2000)(unpublished)(finding that the Piedmont Regional Jail is not a “person” under Section 1983); Roach v. Burch, 825 F.Supp. 116, 117 (N.D.W.Va. 1993)(stating that the West Virginia Regional Jail Authority is not a “person” under Section 1983); also see Will v. Michigan Dept. of State Police, 491 U.S. at 66, 109 S.Ct. at 2309(Suits against a state or state agencies for monetary damages are barred by the Eleventh Amendment to the United States Constitution); Webb v. Parsons, 2011 WL 2076419 (S.D.W.Va. May 6, 2011)(finding that the West Virginia Regional Jail Authority, an agency of the State of West Virginia, is immune from suit under the Eleventh Amendment); but also see Monell v. Dept. of Social Services, 436 U.S. 658, 690, 98 S.Ct. 2018, 56 L.Ed.2d 611 (1978)(Municipalities are “persons” subject to suit

two elements – that ‘the deprivation of [a] basic human need was objectively sufficiently serious,’ and that ‘subjectively the officials act[ed] with a sufficiently culpable state of mind.’” Shakka v. Smith, 71 F.3d 162, 166 (4th Cir. 1995)(quoting Strickler v. Waters, 989 F.2d 1375, 1379 (4th Cir. 1993)(quotation omitted)). See also White v. Gregory, 1 F.3d 267, 269 (4th Cir. 1991)(“In Strickler, we held that a prisoner must suffer ‘serious or significant physical or mental injury’ in order to be ‘subjected to cruel and unusual punishment within the meaning of the’ Eighth Amendment.”)

4 It is insufficient for Plaintiff to name “staff” as a defendant. If Plaintiff is unaware of the names of the relevant individuals, a plaintiff should designate in the case caption each individual whose name is unknown as a John Doe or Jane Doe (e.g. Correctional Officer John Doe) and shall further identify each individual in the body of the Complaint by description, date/time of contact, alleged act, or in some other manner that assists the court in determining the identity and number of individual defendants in the action, as well as the specific reason that each individual defendant is included in the Complaint. Plaintiff is NOTIFIED that service of process cannot be effectuated on “John Doe” or “Jane Doe” defendants. If a defendant is not served, Plaintiff will not be able to prevail on his claim against that person. It is Plaintiff’s responsibility, and not the duty of the Court, to ascertain the identities and addresses of those individuals whom Plaintiff believes caused his injury. 2 under Section 1983); Gilco v. Logan County Commission, 2012 WL 3580056, * 6 (S.D.W.Va. Aug. 17, 2012)(J. Copenhaver)(“Municipalities, such as the County Commission, are ‘persons’ subject to suit under section 1983.") To the extent Plaintiff names Trinity Food Services as defendant, Plaintiff is notified that a private entity that contracts with the State to provide medical services acts “under color of state law.” West v.

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Related

Haines v. Kerner
404 U.S. 519 (Supreme Court, 1972)
Monell v. New York City Dept. of Social Servs.
436 U.S. 658 (Supreme Court, 1978)
Bell v. Wolfish
441 U.S. 520 (Supreme Court, 1979)
Rhodes v. Chapman
452 U.S. 337 (Supreme Court, 1981)
Hudson v. Palmer
468 U.S. 517 (Supreme Court, 1984)
West v. Atkins
487 U.S. 42 (Supreme Court, 1988)
Wilson v. Seiter
501 U.S. 294 (Supreme Court, 1991)
Louis Wolfish v. Honorable Edward Levi
573 F.2d 118 (Second Circuit, 1978)
Jess White v. Ronald O. Gregory Michael House
1 F.3d 267 (Fourth Circuit, 1993)
Farmer v. Brennan
511 U.S. 825 (Supreme Court, 1994)
Roach v. Burke
825 F. Supp. 116 (N.D. West Virginia, 1993)
Austin v. Paramount Parks, Inc.
195 F.3d 715 (Fourth Circuit, 1999)
Shakka v. Smith
71 F.3d 162 (Fourth Circuit, 1995)

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Bluebook (online)
Linkenauger v. Trinity Food Services, Counsel Stack Legal Research, https://law.counselstack.com/opinion/linkenauger-v-trinity-food-services-wvsd-2020.