Loman v. Department of Corrections

CourtDistrict Court, W.D. Kentucky
DecidedJune 6, 2025
Docket5:24-cv-00187
StatusUnknown

This text of Loman v. Department of Corrections (Loman v. Department of Corrections) 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
Loman v. Department of Corrections, (W.D. Ky. 2025).

Opinion

UNITED STATES DISTRICT COURT WESTERN DISTRICT OF KENTUCKY PADUCAH DIVISION

AARON LOMAN PLAINTIFF

v. CIVIL ACTION NO. 5:24-CV-187-JHM

DEPARTMENT OF CORRECTIONS DEFENDANT

MEMORANDUM OPINION Plaintiff Aaron Loman filed the instant pro se 42 U.S.C. § 1983 action1 proceeding in forma pauperis on December 13, 2024 (DN 1). The complaint is before the Court for screening pursuant to 28 U.S.C. § 1915(e) and McGore v. Wrigglesworth, 114 F.3d 601, 608-09 (6th Cir. 1997), overruled on other grounds by Jones v. Bock, 549 U.S. 199 (2007). For the reasons stated below, the Court will dismiss the action without prejudice to filing an amended complaint. I. STATEMENT OF CLAIMS Plaintiff’s allegations concern what appears to be a period of previous incarceration at the Kentucky State Penitentiary (KSP).2 He sues “D.O.C. Kentucky State Penitentiary” in its official capacity and “Wellpath” with no designated capacity. Plaintiff’s complaint alleges that the following occurred at KSP on July 22, 2022, at 10:30 a.m.: “I came to medical to be treated for an infection on my foot. Anna Murphy the provider told me to deal with it myself an[d] she would not give me antibiotics and to buy my own BandAid[.] It resulted in me having a 1/4 of my foot amputated.”

1 Plaintiff’s complaint indicates that he is bringing suit against Federal officials pursuant to Bivens v. Six Unknown Named Agents of Fed. Bureau of Narcotics, 403 U.S. 388 (1971). The Court construes his complaint as arising under 42 U.S.C. § 1983 insofar as he names only state agencies or actors as Defendants. 2 While the complaint indicates that Plaintiff was incarcerated at one time, it does not appear he is currently confined, and the complaint was filed after his release. Accordingly, the Court will review the complaint under § 1915(e), rather than § 1915A, which applies to “a civil action in which a prisoner seeks redress from a governmental entity or officer or employee of a governmental entity.” § 1915A(a). However, the outcome is the same under either standard. As relief, Plaintiff seeks monetary damages. II. STANDARD OF REVIEW Because Plaintiff is proceeding in forma pauperis, the Court must review the complaint under 28 U.S.C. § 1915(e). McGore, 114 F.3d at 608-09 (6th Cir. 1997). On review, a district court must dismiss a case at any time if it determines that 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. 28 U.S.C. § 1915(e)(2)(B). 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)). The 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 (1972); Jourdan v. Jabe, 951 F.2d 108, 110 (6th Cir. 1991). However, this duty “does not require us to conjure up unpled allegations.” McDonald v. Hall, 610 F.2d 16, 19 (1st Cir. 1979).

III. ANALYSIS Section 1983 creates no substantive rights but merely provides remedies for deprivations of rights established elsewhere. Flint ex rel. Flint v. Ky. Dep’t of Corr., 270 F.3d 340, 351 (6th Cir. 2001). Two elements are required to state a claim under § 1983. Gomez v. Toledo, 446 U.S. 635, 640 (1980). “A plaintiff must allege the violation of a right secured by the Constitution and laws of the United States, and must show that the alleged deprivation was committed by a person acting under color of state law.” West v. Atkins, 487 U.S. 42, 48 (1988). “Absent either element, a section 1983 claim will not lie.” Christy v. Randlett, 932 F.2d 502, 504 (6th Cir. 1991). Because § 1983 does not provide a statute of limitations, federal courts borrow the forum state’s statute of limitations for personal injury actions. Wilson v. Garcia, 471 U.S. 261, 275-80 (1985). In Kentucky, § 1983 actions are limited by the one-year statute of limitations found in Ky. Rev. Stat. § 413.140(1)(a). Collard v. Ky. Bd. of Nursing, 896 F.2d 179, 182 (6th Cir. 1990). However, federal law determines when a § 1983 claim accrues to trigger the running of this state

statute of limitations. Wallace v. Kato, 549 U.S. 384, 387-88 (2007).3 The Court construes the complaint as alleging a claim of deliberate indifference to serious medical needs under the Eighth Amendment. See Estelle v. Gamble, 429 U.S. 97 (1976); Farmer v. Brennan, 511 U.S. 825 (1994). As to the Defendant named “D.O.C. Kentucky State Penitentiary,” the Court observes that KSP is part of the Kentucky Department of Corrections (KDOC), both of which are agencies or entities of the Commonwealth of Kentucky. See Ky. Rev. Stat. § 15A.020. A state and its agencies, however, are not “persons” subject to suit under § 1983. Will v. Mich. Dep’t of State Police, 491 U.S. 58, 71 (1989); see also Crockett v. Turney Ctr. Indus. Prison, No. 96-6067,

121 F.3d 707, 1997 WL 436563, at *1 (6th Cir. Aug. 1, 1997) (“The prison is a state agency . . . . A state agency is not considered a ‘person’ subject to suit under 42 U.S.C. § 1983.”). Because neither KSP nor KDOC is a “person” for purposes of § 1983, Plaintiff’s claim against D.O.C.

3 The Court notes that there remains some uncertainty as to the standard applied regarding the commencement of the statute of limitations in § 1983 cases. As observed by a recent Sixth Circuit decision, the Supreme Court has recited a “standard” or “occurrence” rule which starts a limitations period when “the plaintiff has a complete and present cause of action.” Reguli v. Russ, 109 F.4th 874, 879 (6th Cir. 2024) (citations and quotations omitted).

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Related

Haines v. Kerner
404 U.S. 519 (Supreme Court, 1972)
Estelle v. Gamble
429 U.S. 97 (Supreme Court, 1976)
Monell v. New York City Dept. of Social Servs.
436 U.S. 658 (Supreme Court, 1978)
Gomez v. Toledo
446 U.S. 635 (Supreme Court, 1980)
Polk County v. Dodson
454 U.S. 312 (Supreme Court, 1981)
Wilson v. Garcia
471 U.S. 261 (Supreme Court, 1985)
West v. Atkins
487 U.S. 42 (Supreme Court, 1988)
Will v. Michigan Department of State Police
491 U.S. 58 (Supreme Court, 1989)
Bell Atlantic Corp. v. Twombly
550 U.S. 544 (Supreme Court, 2007)
Wallace v. Kato
127 S. Ct. 1091 (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)
Farmer v. Brennan
511 U.S. 825 (Supreme Court, 1994)

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