Perez v. Huneycutt

CourtDistrict Court, W.D. North Carolina
DecidedAugust 16, 2022
Docket5:22-cv-00076
StatusUnknown

This text of Perez v. Huneycutt (Perez v. Huneycutt) is published on Counsel Stack Legal Research, covering District Court, W.D. North Carolina primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Perez v. Huneycutt, (W.D.N.C. 2022).

Opinion

IN THE UNITED STATES DISTRICT COURT FOR THE WESTERN DISTRICT OF NORTH CAROLINA STATESVILLE DIVISION CIVIL CASE NO. 5:22-cv-00076-MR

OSCAR PEREZ, ) ) Plaintiff, ) ) vs. ) ) FNU HUNEYCUTT, et al., ) ORDER ) Defendants. ) _______________________________ )

THIS MATTER is before the Court on initial review of the pro se Complaint [Doc. 1]. Also pending is the Plaintiff’s Motion Requesting Class Action Certification [Doc. 7]. I. BACKGROUND The pro se incarcerated Plaintiff filed this civil rights action pursuant to 42 U.S.C. § 1983 addressing incidents that allegedly occurred at the Alexander Correctional Institution, where he is presently incarcerated. [Doc. 1]. He names as Defendants: FNU Huneycutt, the warden; FNU Dye and FNU Duncan, assistant wardens; and John Doe, the captain of Green Unit. [Id. at 1]. He alleges that the Defendants were deliberately indifferent to his need to exercise, which they denied him without due process and, as a result he has gained 12-15 pounds; he developed high blood pressure and high cholesterol; he has experienced increased anxiety and depression; he has constant headaches; and his life expectancy has decreased. [Id. at 3, 7-8].

He seeks compensatory, nominal and punitive damages, a declaratory judgment, injunctive relief, and a jury trial. [Id. at 9]. The Plaintiff has also filed a Motion asking the Court to certify as a

class “all inmates confined at Alexander Correctional Institution, past, current, and future, who have a mental health Code 3 diagnosis, high blood pressure, high cholesterol, overweight, diabetes, and cardiac issues.” [Doc. 7 at 1].

II. STANDARD OF REVIEW Despite the Plaintiff’s payment of the filing fee, the Court must conduct an initial review and identify and dismiss the complaint, or any portion of the

complaint, if it is frivolous, malicious, or fails to state a claim upon which relief may be granted; or seeks monetary relief from a defendant who is immune to such relief. 28 U.S.C. § 1915A. In its frivolity review, this Court must determine whether the Complaint

raises an indisputably meritless legal theory or is founded upon clearly baseless factual contentions, such as fantastic or delusional scenarios. Neitzke v. Williams, 490 U.S. 319, 327-28 (1989). Furthermore, a pro se

complaint must be construed liberally. Haines v. Kerner, 404 U.S. 519, 520 (1972). However, the liberal construction requirement will not permit a district court to ignore a clear failure to allege facts in his Complaint which

set forth a claim that is cognizable under federal law. Weller v. Dep’t of Soc. Servs., 901 F.2d 387 (4th Cir. 1990). III. DISCUSSION

To state a claim under § 1983, a plaintiff must allege that he was “deprived of a right secured by the Constitution or laws of the United States, and that the alleged deprivation was committed under color of state law.” Am. Mfrs. Mut. Ins. Co. v. Sullivan, 526 U.S. 40, 49-50 (1999).

A. Conditions of Confinement The Plaintiff claims that Defendant Huneycutt made a “direct order” not to allow outdoor exercise; that Defendants Dye and Duncan made decisions

about inmates’ exercise schedule, which was very restricted; that Duncan reviewed grievances “about inmates not being given the opportunity to properly exercise,” and failed to correct the situation; and that Defendant John Doe would have known that inmates were not given the opportunity to

exercise had he reviewed video and logs. [Doc. 1 at 3-5]. As a result of the foregoing, the Plaintiff claims that he was only able to exercise for 10-15 hours during all of 2021, and that his ability to exercise improved somewhat

in 2022 but is still very limited. [Id. at 3-6]. He claims that his physical and mental health have deteriorated as a result of the Defendants’ deliberate indifference. [Id. at 7-9].

The Eighth Amendment protects prisoners from inhumane methods of punishment and from inhumane conditions of confinement. Williams v. Benjamin, 77 F.3d 756, 761 (4th Cir. 1996). “Prison conditions may be harsh

and uncomfortable without violating the Eighth Amendment prohibition against cruel and unusual punishment.” Dixon v. Godinez, 114 F.3d 640, 642 (7th Cir. 1997). Rather, extreme deprivations are required, and “only those deprivations denying the minimal civilized measure of life’s necessities

are sufficiently grave to form the basis of an Eighth Amendment violation.” Hudson v. McMillian, 503 U.S. 1, 9 (1992) (quoting Wilson v. Seiter, 501 U.S. 294, 298 (1991) (internal quotation omitted)). Further, a plaintiff must allege

and prove facts sufficient to support a claim that prison officials knew of and disregarded a substantial risk of serious harm. See Farmer v. Brennan, 511 U.S. 825, 847 (1994). To establish liability under 42 U.S.C. § 1983, a plaintiff must show that

the defendants “acted personally” to cause the alleged violation. See Vinnedge v. Gibbs, 550 F.2d 926, 928 (4th Cir. 1977) (citation omitted). As such, the doctrine of respondeat superior does not apply in actions brought

under § 1983. See Monell v. Dep’t of Soc. Servs. of NY, 436 U.S. 658, 694 (1978). However, a supervisor can be liable where (1) he knew that his subordinate “was engaged in conduct that posed a pervasive and

unreasonable risk of constitutional injury;” (2) his response showed “deliberate indifference to or tacit authorization of the alleged offensive practices;” and (3) that there was an “affirmative causal link” between his inaction and the constitutional injury.” Shaw v. Stroud, 13 F.3d 791, 799 (4th

Cir. 1994) (internal quotation marks omitted). Taking the Plaintiff’s allegations as true for the purposes of initial review and drawing all reasonable inferences in his favor, the Plaintiff has

made sufficient allegations to allow a claim against Defendants Huneycutt, Dye, and Duncan for exposing him to unconstitutional conditions of confinement to proceed to discovery. However, the Plaintiff’s claim against

Defendants John Doe appears to be based on respondeat superior and is dismissed. B. Deliberate Indifference to a Serious Medical Need The Plaintiff claims that the Defendants are deliberately indifferent to

his serious mental health and medical needs by restricting his movement, exercise, and outdoor recreation. [Doc. 1 at 3]. He claims that he is a Code 3 mental health inmate who takes medication, and that the conditions at

Alexander CI have increased his anxiety and depression. [Id. at 6].

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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)
Neitzke v. Williams
490 U.S. 319 (Supreme Court, 1989)
Wilson v. Seiter
501 U.S. 294 (Supreme Court, 1991)
Hudson v. McMillian
503 U.S. 1 (Supreme Court, 1992)
Sandin v. Conner
515 U.S. 472 (Supreme Court, 1995)
Farmer v. Brennan
511 U.S. 825 (Supreme Court, 1994)
Alfredo Prieto v. Harold Clarke
780 F.3d 245 (Fourth Circuit, 2015)
Williams v. Benjamin
77 F.3d 756 (Fourth Circuit, 1996)
Shaw v. Stroud
13 F.3d 791 (Fourth Circuit, 1994)
Myers v. Loudoun County Public Schools
418 F.3d 395 (Fourth Circuit, 2005)
Oxendine v. Williams
509 F.2d 1405 (Fourth Circuit, 1975)
Hummer v. Dalton
657 F.2d 621 (Fourth Circuit, 1981)
Miltier v. Beorn
896 F.2d 848 (Fourth Circuit, 1990)

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Perez v. Huneycutt, Counsel Stack Legal Research, https://law.counselstack.com/opinion/perez-v-huneycutt-ncwd-2022.