Morales v. Cassidy

District Court, E.D. Tennessee·Decided September 4, 2025·No. 3:25-cv-00325·Unknown

Opinion

UNITED STATES DISTRICT COURT EASTERN DISTRICT OF TENNESSEE AT KNOXVILLE

MATTHEW MORALES, ) ) Case No. 3:25-CV-325-TRM-JEM Plaintiff, ) ) Judge Travis R. McDonough v. ) ) Magistrate Judge Jill E. McCook SHERIFF JEFF CASSIDY, ) ) Defendant. )

MEMORANDUM & ORDER

Plaintiff, a Sullivan County Detention Center inmate, filed a pro se complaint for violation of 42 U.S.C. § 1983 asserting that the lights in his cell and the dayroom adjacent to his cell are only reduced for four hours at night (Doc. 1) and a motion for leave to proceed in forma pauperis (Doc. 4). The Court will address Plaintiff’s motion (Id.) before screening his complaint (Doc. 1). I. MOTION FOR LEAVE TO PROCEED IN FORMA PAUPERIS As Plaintiff cannot pay the filing fee in one lump sum, his motion for leave to proceed in forma pauperis (Doc. 4) is GRANTED. Plaintiff is ASSESSED the civil filing fee of $350.00. 28 U.S.C. § 1914(a). The custodian of his inmate account is DIRECTED to submit to the Clerk, U.S. District Court, 800 Market Street, Suite 130, Knoxville, Tennessee 37902, as an initial partial payment, whichever is the greater of: (a) twenty percent (20%) of the average monthly deposits to his inmate account; or (b) twenty percent (20%) of the average monthly balance in his inmate account for the six- month period preceding the filing of the complaint. 28 U.S.C.§ 1915(b)(1)(A) and (B). Thereafter, the custodian of Plaintiff’s inmate account is directed to submit twenty percent (20%) of his preceding monthly income (or income credited to his trust account for the preceding month), but only when such monthly income exceeds ten dollars ($10.00), until this filing fee has been paid. 28 U.S.C. § 1915(b)(2). The Clerk is DIRECTED to send a copy of this memorandum and order to the Court’s financial deputy and the custodian of inmate accounts at Plaintiff’s facility to ensure payment.

This memorandum and order shall be placed in Plaintiff’s file and follow him if he is transferred. II. COMPLAINT SCREENING A. Standard District courts must screen prisoner complaints and dismiss any claims that are frivolous or malicious, fail to state a claim for relief, or are against a defendant who is immune. See 28 U.S.C. §§ 1915(e)(2)(B) and 1915A; Benson v. O’Brian, 179 F.3d 1014 (6th Cir. 1999). The dismissal standard the Supreme Court set forth in Ashcroft v. Iqbal, 556 U.S. 662 (2009) and Bell Atlantic Corp. v. Twombly, 550 U.S. 544 (2007) “governs dismissals for failure to state a claim [at screening] because the relevant statutory language tracks the language in Rule 12(b)(6).” Hill

v. Lappin, 630 F.3d 468, 470–71 (6th Cir. 2010). Thus, to survive an initial review, a prisoner complaint “must contain sufficient factual matter, accepted as true, to ‘state a claim to relief that is plausible on its face.’” Iqbal, 556 U.S. at 678 (quoting Twombly, 550 U.S. at 570). Formulaic and conclusory recitations of the elements of a claim do not state a plausible claim for relief. Id. at 681. Likewise, an allegation that does not raise a plaintiff’s right to relief “above a speculative level” fails to state a plausible claim. Twombly, 550 U.S. at 570. However, courts liberally construe pro se pleadings and hold them to a less stringent standard than lawyer- drafted pleadings. Haines v. Kerner, 404 U.S. 519, 520 (1972). A claim for violation of 42 U.S.C. § 1983 requires a plaintiff to establish that a person acting under color of state law deprived him a federal right. 42 U.S.C. § 1983. B. Allegations In his complaint, Plaintiff first indicates that although the Sullivan County Jail has a grievance process, he did not file a grievance regarding the claim in his complaint because that

process “is only set-up to allow grievances against individual shifts” (Doc. 1, at 2). As to the substantive claim in his complaint, Plaintiff states that the lights in his cell and in the dayroom adjacent to his cell are only reduced from 12 a.m. to 4 a.m., and that he therefore uses his sheet as a “makeshift sleeping mask” (Doc. 1, at 4). Plaintiff has sued Sullivan County Sheriff Jeff Cassidy and requests injunctive relief that forces the jail to turn off the lights for four hours at night (Id. at 1, 3, 5). C. Analysis First, Plaintiff’s complaint is subject to dismissal because it is apparent from the face of the complaint that Plaintiff did not exhaust his available administrative remedies prior to filing

this action. Additionally, even if the Court could excuse Plaintiff’s failure to file a grievance regarding the claim in his complaint, the complaint would still be subject to dismissal, as it fails to state a plausible claim for relief under § 1983 against Defendant Sheriff Cassidy in his individual or official capacity. The Court presumes that Plaintiff is a pretrial detainee for purposes of screening his complaint. Brawner v. Scott Cnty., 14 F.4th 585, 596 (6th Cir. 2021). 1. Failure to Exhaust First, it is apparent from the face of his complaint that Plaintiff did not exhaust his administrative remedies prior to filing this action. The PLRA provides that “[n]o action shall be brought with respect to prison conditions under section 1983 of this title, or any other Federal law, by a prisoner confined in any jail, prison, or other correctional facility until such administrative remedies as are available are exhausted.” 42 U.S.C. § 1997e(a). The exhaustion requirement of the PLRA is one of “proper exhaustion.” Woodford v. Ngo, 548 U.S. 81, 93 (2006). This means the prisoner plaintiff must complete “the administrative review process in accordance with the applicable procedural rules, including deadlines, as a precondition to bringing suit in federal court.” Id. at 88. To properly exhaust his claims, a prisoner must utilize

every step of the prison’s procedure for resolving his grievance and follow the “critical procedural rules” in a manner that allows prisoner officials to review and, where necessary, correct the issues set forth in the grievance “on the merits.” Troche v. Crabtree, 814 F.3d 795, 798 (6th Cir. 2016) (quoting Woodford, 548 U.S. at 81, 95)). While failure to exhaust administrative remedies is an affirmative defense that “inmates are not required to specially plead or demonstrate . . . in their complaints,” a complaint that sets forth allegations which, taken as true, establish that the plaintiff has failed to exhaust his available administrative remedies is subject to dismissal for failure to state a claim upon which relief may be granted. Jones v.

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