McNeal v. McCuiston

CourtDistrict Court, W.D. Kentucky
DecidedApril 12, 2023
Docket5:22-cv-00101
StatusUnknown

This text of McNeal v. McCuiston (McNeal v. McCuiston) 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
McNeal v. McCuiston, (W.D. Ky. 2023).

Opinion

UNITED STATES DISTRICT COURT WESTERN DISTRICT OF KENTUCKY PADUCAH DIVISION

TIMOTHY COLE McNEAL PLAINTIFF v. CIVIL ACTION NO. 5:22-cv-101-BJB LT. McCUISTION SLADE et al. DEFENDANTS MEMORANDUM OPINION AND ORDER Pro se Plaintiff Timothy Cole McNeal brought this 42 U.S.C. § 1983 lawsuit. This matter is before the Court for screening pursuant to 28 U.S.C. § 1915A and McGore v. Wrigglesworth, 114 F.3d 601, 604 (6th Cir. 1997), overruled on other grounds by Jones v. Bock, 549 U.S. 199 (2007). For the following reasons, the Court dismisses some of Plaintiff’s claims but allows Plaintiff to file an amended Complaint. Plaintiff has also filed a motion for default judgment. The Defendants, however, are not in default because they have not been served with process. Under § 1915A, this case must be screened beforehand, “and no process will be served in the case unless the Court orders such service.” Greene v. Gaylor, No. 15-2209, 2016 WL 1178815, at *1 (W.D. Tenn. Mar. 24, 2016). The Court, therefore, denies Plaintiff’s motion (DN 14). I. STATEMENT OF CLAIMS Plaintiff, a detainee at the Calloway County Jail (CCJ) when he filed his complaint, sues the jail and CCJ Lt. Deputy Jailer McCuistion Slade in his individual and official capacities. The Complaint describes ongoing racially charged mistreatment by jail staff. Plaintiff states that each day since his arrest on July 1, 2022, he was searched with a body scanner and strip searched and that on July 7 drugs were “planted” on him. DN 1, p. 4. According to Plaintiff, his “cellie,” who was white, was caught with drugs so “they plant[ed] his drugs on me and charge[d] me,” rather than “both of us.” Id. “[T]o make matters worse,” he continues, “I was put in isolation for failing a drug test fresh off the streets.” Id. Plaintiff alleges that he was charged with contraband and received 90 days in isolation, a penalty that he believes amounts to double jeopardy. Id. at 5. He also states that he was held for “over a month without a bond or seeing pretrial on these contraband charges.” Id.

Also, according to the Complaint, on July 19, 2022 Plaintiff was awakened and called to booking to sign something. Id. at 4. He states that when he asked to read this material before he signed it, he was pepper sprayed, despite showing no aggression and having his hands up and palms out the entire time. Id. Plaintiff alleges that he was then threatened with being tased, strapped in a chair, and hosed down with water even though he still was not acting in an aggressive manner. Id. Next, Plaintiff alleges that the second- and third-shift employees constantly threatened him, “called racial remarks,” and taunted him. Id. According to Plaintiff, there is no ethnic diversity in the CCJ. Id. He states that, for a week, every time that Defendant Slade passed his

door, he said, “How you like that[,] n*****.” Id. at 4-5. “I’ve been strip searched for punishment and made gay slurs at,” he asserts, and overheard Defendant Slade “say strip his Black n***** ass to one of his guards.” Id. at 5. Plaintiff further alleges that when he tried to report Defendant Slade to his supervisors, “they wait till he shows up to work then they show up together to talk to me. This is cruel and unusual punishment and downright criminal.” Id. (cleaned up). Plaintiff also alleges, “I feel like he [presumably Slade] is trying to keep the situation in house so it[’]s brushed under the rug. I file grievances[.] [I]nstead of the grievance officer seeing what the complaint is about I’m constantly getting confronted by Lt. Slade. I’m not sure but this feels wrong and unconstitutional and down right against the law.” Id. As relief, Plaintiff requests damages and injunctive relief: specifically, that the “officers involved [be] charged and put in jail,” and that the Court order them to “never work in law enforcement again.” Id. at 6.

II. STANDARD OF REVIEW When a prisoner sues a governmental entity, officer, or employee, the trial court must review the complaint and dismiss the case if it 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 28 U.S.C. § 1915A(b)(1) and (2). When screening the complaint, the Court must construe it in the light most favorable to Plaintiff and accept well-pled allegations as true. Hill v. Lappin, 630 F.3d 468, 471 (6th Cir. 2010). And while a reviewing court liberally construes pro se pleadings, see id. at 471; Boag v. MacDougall, 454 U.S. 364, 365 (1982), a complaint must include “enough facts to state a claim to relief that is plausible on its face” in

order to avoid dismissal, Bell Atl. Corp. v. Twombly, 550 U.S. 544, 570 (2007). III. ANALYSIS A. Claims against the CCJ and Defendant Slade in his official capacity First, CCJ is not a “person” subject to suit under § 1983 because municipal departments, such as jails, are not suable under § 1983. Rhodes v. McDannel, 945 F.2d 117, 120 (6th Cir. 1991) (holding that a police department may not be sued under § 1983); see also Marbry v. Corr. Med. Serv., No. 99-6706, 2000 WL 1720959, at *2 (6th Cir. Nov. 6, 2000) (holding that a jail is not an entity subject to suit under § 1983). In this situation, Calloway County would be the proper defendant. Smallwood v. Jefferson Cnty. Gov’t, 743 F. Supp. 502, 503 (W.D. Ky. 1990) (construing claims brought against the Jefferson County Government, the Jefferson County Fiscal Court, and the Jefferson County Judge Executive as claims against Jefferson County itself). Further, Calloway County is a “person” for purposes of § 1983. Monell v. N.Y. Dep’t of Soc. Servs., 436 U.S. 658, 690 (1978). The Court will therefore construe the claims against CCJ as brought against Calloway County.

Similarly, claims against a corrections or law-enforcement employee in his official capacity must be construed as running against the governmental entity employing him. Will v. Mich. Dep’t of State Police, 491 U.S. 58, 71 (1989). So the claims against Defendant Slade in his official capacity are in effect brought against Calloway County. See Matthews v. Jones, 35 F.3d 1046, 1049 (6th Cir. 1994). The Supreme Court has recognized that a municipal government, like Calloway County, is not automatically liable for “an injury inflicted solely by its employees or agents.” Monell, 436 U.S. at 694. “[A] municipality cannot be held liable solely because it employs a tortfeasor.” Id. at 691 (emphasis in original); see also Gregory v. City of Louisville, 444 F.3d 725, 752 (6th

Cir. 2006) (no vicarious liability for constitutional violations committed by city employees).

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Bluebook (online)
McNeal v. McCuiston, Counsel Stack Legal Research, https://law.counselstack.com/opinion/mcneal-v-mccuiston-kywd-2023.