Meadows v. Federal Bureau of Prisons

CourtDistrict Court, S.D. Mississippi
DecidedAugust 8, 2025
Docket3:24-cv-00410
StatusUnknown

This text of Meadows v. Federal Bureau of Prisons (Meadows v. Federal Bureau of Prisons) is published on Counsel Stack Legal Research, covering District Court, S.D. Mississippi primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Meadows v. Federal Bureau of Prisons, (S.D. Miss. 2025).

Opinion

IN THE UNITED STATES DISTRICT COURT FOR THE SOUTHERN DISTRICT OF MISSISSIPPI NORTHERN DIVISION

LEWIS MEADOWS PLAINTIFF

V. CIVIL ACTION NO. 3:24-CV-410-HTW-LGI

FEDERAL BUREAU OF PRISONS, ET AL. DEFENDANTS REPORT AND RECOMMENDATION OF UNITED STATES MAGISTRATE JUDGE

Lewis Meadows files this action against medical staff at the Federal Bureau of Prison (“BOP”). Liberally construed, Meadows alleges that while housed at the Federal Correctional Complex in Yazoo City, Mississippi, (“FCC-Yazoo”),1 Dr. Anthony Chambers, identified as the head physician, and Cynthis McGee, identified as the Health Services Supervisor,2 provided inadequate medical care regarding his cancer treatment. Meadows charges that Defendants were negligent in their “refusal to get [him] medical care in a timely manner” and in their communications with “outside doctors.” According to Meadows, this “resulted in unnecessary pain and misery as well as a botched surgery that was done wrong, resulting in serious damage. . . .” Along with monetary damages, Meadows requests that he be seen by a specialist or transferred to a new medical facility to manage his care going forward. Defendants contend that dismissal is warranted under Fed. R. Civ. P. 12(b)(6), or in the alternative, for summary judgment under Fed. R. Civ. P. 56, on exhaustion,

1 The docket reflects that since filing suit, Plaintiff has been transferred to FDC Miami.

2 Defendants do not contest Meadows’s assertion that Defendant McGee is the Health Services Supervisor at FCC-Yazoo. jurisdiction, and immunity grounds. Meadows has not filed a response to Defendants’ motion, and the time for doing so has passed. Having considered the submissions on file

and the applicable law, the undersigned recommends that Defendants’ motion be granted. STANDARD OF REVIEW Because Defendants have submitted matters outside the pleadings with their Motion to Dismiss or, in the Alternative, for Summary Judgment, the undersigned has considered the motion as one seeking summary judgment. See Fed. R. Civ. P. 12(b); Young v. Biggers, 938 F.2d 565, 568 (5th Cir. 1991). Summary judgment is appropriate only when the moving party can show that “there is no genuine dispute as to

any material fact and the movant is entitled to judgment as a matter of law.” Fed. R. Civ. P. 56(a). A dispute is genuine if the evidence is such that a reasonable jury could return a verdict for the non-movant. Nickell v. Beau View of Biloxi, L.L.C., 636 F.3d 752, 754 (5th Cir. 2011) (citing Anderson v. Liberty Lobby, Inc., 477 U.S. 242, 248, 106 S. Ct. 2505, 91 L. Ed. 2d 202 (1986)). A fact is material if its resolution in favor of one party

might affect the outcome. Anderson, 477 U.S. at 248. The evidence and any inferences from it are viewed in the light most favorable to the non-movant. First Colony Life Ins. Co. v. Sanford, 555 F.3d 177, 180 (5th Cir. 2009). DISCUSSION Liberally construed, Meadows seeks relief pursuant to Bivens v. Six Unknown

Named Agents of Fed. Bureau of Narcotics, 403 U.S. 388 (1971) on the grounds of deliberate indifference. In Bivens, the United States Supreme Court recognized a cause of action for monetary relief for constitutional violations by federal officials as the counterpart for actions brought against state officials pursuant to 42 U.S.C. § 1983. Bivens, 403 U.S. at 389–98. Unlike § 1983, Bivens is not a Congressional statute

that “entitles an injured person to money damages if a state official violates his or her constitutional rights.” Ziglar v. Abbasi, 582 U.S. 120, 137 S. Ct. 1843, 1854, 198 L. Ed. 2d 290 (2017). It was created as a judicial remedy in 1979 to address a Fourth Amendment claim for unreasonable search and seizure. Bivens, 403 U.S. at 389–90 (manacling the plaintiff in front of his family in his home and strip-searching him in violation of the Fourth Amendment). Since then, the Supreme Court has only extended

Bivens beyond the deprivation of Fourth Amendment rights twice: for violations of the Fifth Amendment Due Process Clause for gender discrimination, Davis v. Passman, 442 U.S. 228, 99 S. Ct. 2264, 60 L. Ed. 2d 846 (1979), and for violations of the Eighth Amendment prohibition against cruel and unusual punishment for a deceased prisoner deprived of medical attention by officials who knew of his serious medical condition,

Carlson v. Green, 446 U.S. 14, 100 S. Ct. 1468, 64 L. Ed. 2d 15 (1980); Butts v. Martin, 877 F.3d 571, 571 (5th Cir. 2017) (citation omitted). “These three cases—Bivens, Davis, and Carlson—represent the only instances in which the Court has approved of an implied damages remedy under the Constitution itself.” See Ziglar, 137 S. Ct. at 1855. In the decades since, “the Court has made clear that expanding the Bivens remedy is now a

disfavored judicial activity.” Ziglar, 137 S. Ct. at 1865–69 (quoting Ashcroft v. Iqbal, 556 U.S. 662, 675, 129 S. Ct. 1937, 173 L. Ed. 2d 868 (2009)). The Supreme Court has even “gone so far as to observe that if the Court’s three Bivens cases [had] been . . . decided today, it is doubtful that [it] would have reached the same result.” Hernandez v. Mesa, — U.S.—, 140 S. Ct. 735, 206 L. Ed. 2d 29 (2020) (internal quotation marks omitted) (“for almost 40 years, we have consistently rebuffed requests to add to the claims allowed

under Bivens”). The rationale being that “Congress is best positioned to evaluate whether, and the extent to which, monetary and other liabilities should be imposed upon individual officers and employees of the Federal Government based on constitutional torts.” Id. (internal quotation marks omitted). Accordingly, lower courts should conduct a two-part inquiry to determine whether a Bivens remedy should be extended: (1) whether the Bivens claim represents a new

context, and if so, (2) whether there are any existing remedial processes for addressing the alleged harm or other special factors counseling hesitation against extending Bivens. Oliva v. Nivar, 973 F.3d 438, 441–42 (5th Cir. 2020); Cantu v. Moody, 933 F.3d 414, 422 (5th Cir. 2019)); Rroku v. Cole, 726 F. App’x 201, 205 (5th Cir. 2018) (citing Butts, 877 F.3d at 587). Lower courts are cautioned, however, that “if there is an alternative

remedial structure present in a certain case, that alone may limit the power of the Judiciary to infer a new Bivens cause of action.” Ziglar, 137 S. Ct. at 1858. Such is the case here.

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Related

Fuller v. Rich
11 F.3d 61 (Fifth Circuit, 1994)
Schipke v. Van Buren
239 F. App'x 85 (Fifth Circuit, 2007)
First Colony Life Insurance v. Sanford
555 F.3d 177 (Fifth Circuit, 2009)
Davis v. Passman
442 U.S. 228 (Supreme Court, 1979)
Carlson v. Green
446 U.S. 14 (Supreme Court, 1980)
Anderson v. Liberty Lobby, Inc.
477 U.S. 242 (Supreme Court, 1986)
Hui v. Castaneda
559 U.S. 799 (Supreme Court, 2010)
Ashcroft v. Iqbal
556 U.S. 662 (Supreme Court, 2009)
Nickell v. Beau View of Biloxi, L.L.C.
636 F.3d 752 (Fifth Circuit, 2011)
Ricardo Gallegos-Hernandez v. USA
688 F.3d 190 (Fifth Circuit, 2012)
Ziglar v. Abbasi
582 U.S. 120 (Supreme Court, 2017)
Paul Butts v. Marcus Martin
877 F.3d 571 (Fifth Circuit, 2017)
Daniel Cantu v. James Moody
933 F.3d 414 (Fifth Circuit, 2019)
Hernandez v. Mesa
589 U.S. 93 (Supreme Court, 2020)

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Meadows v. Federal Bureau of Prisons, Counsel Stack Legal Research, https://law.counselstack.com/opinion/meadows-v-federal-bureau-of-prisons-mssd-2025.