Porter v. Hamilton

CourtDistrict Court, E.D. Virginia
DecidedMarch 2, 2022
Docket1:20-cv-00203
StatusUnknown

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

Bluebook
Porter v. Hamilton, (E.D. Va. 2022).

Opinion

IN THE UNITED STATES DISTRICT COURT FOR THE EASTERN DISTRICT OF VIRGINIA Alexandria Division Travis Porter, ) Plaintiff, ) v. ) 1:20cv203 (RDA/IDD) I. Hamilton, et al., ) Defendants. ) MEMORANDUM OPINION Travis Porter (“Porter” or “Plaintiff’), a Virginia inmate proceeding pro se, filed a civil rights action under 42 U.S.C. § 1983. [Dkt. No. 1]. In his second amended complaint, Porter alleged that the defendants Israel Hamilton, Warden; Lt. Sawyer, Building Lieutenant; Penden, Counselor; Sgt. Stephenson, Night Shift Sergeant; Lt. Jackson, Watch Commander; Harris, Head of Medical; and “Jane Doe,” Nurse, violated his Eighth Amendment rights by not protecting him from an attack by another inmate and by delaying adequate medical care for the injury he sustained as a result of the attack while he was detained at the Virginia Department of Corrections (“VDOC”) Sussex I State Prison (Sussex I). [Dkt. No. 20]. Defendants Hamilton and Jackson moved for summary judgment, Porter responded, and the Court granted that motion for summary judgment on April 15, 2021. [Dkt. Nos. 39, 42]. Defendants Sawyer, Penden, and Stephenson filed a motion for summary judgment on June 11, 2021, supported by a brief and exhibits [Dkt. Nos. 51, 52], which is addressed in a separate memorandum opinion. The matter is presently before the Court on Defendant Harris’s motion to dismiss. Plaintiff has been afforded the opportunity to file responsive materials to Defendant Harris’s motion to dismiss pursuant to Roseboro v. Garrison, 528 F.2d 309 (4th Cir. 1975), and he responded by seeking a temporary restraining order, discovery, motions to appoint counsel, a

motion to compel discovery and a declaration in opposition to the motion for summary judgment. [Dkt. Nos. 56-58, 62, 63, 65, 68, 70]. The Court directed the defendants to respond to several of the motions [Dkt. No. 61], and denied the motions in a separate order entered November 17, 2021. [Dkt. No. 71]. Accordingly, this matter is now ripe for disposition. For the reasons that follow, Defendant Harris’s motion to dismiss must be granted. I. Second Amended Complaint Plaintiff alleges that he was injured by another inmate at 9:45 p.m. on October 30, 2019 while he was detained at the Sussex I State Prison (“Sussex I”). The inmate stabbed plaintiff under his left eye. [Dkt. No. 20 at 7]. Plaintiff was placed in a shower at approximately 10:00 p.m. and then taken to the medical unit at 2:45 a.m. on October 31, 2019. Plaintiff was treated by the nurse on duty with Neosporin, the nurse applied a band aid, and told plaintiff “it was just a scratch.” [Id. at 8]. Plaintiff was seen again on November 4, 2019 and the medical provider who “pulled [pieces] of plastic from [his] face,” and fluid was also “leaking” from plaintiff's face. [Id.]. An x-ray on January 4, 2020 showed a piece of metal was “lodged” in plaintiff's face that required surgery to remove. [Id.]. Plaintiff was transferred from Sussex I on February 21, 2020. [Id. at 9]. The second amended complaint names Harris as a defendant, but does not contain any specific allegations connecting him to either Sussex I where plaintiff was detained at that time or to his treatment at the medical unit. The only reference to Harris that appears anywhere in the second amended complaint alleges that he was “Head of Medical on 10-31-19.” [Id. at 3]. Il. Standard of Review A motion to dismiss tests whether a complaint states a cause of action upon which relief

can be granted. Whether a complaint sufficiently states a claim is determined by “the familiar standard ... under Fed. R. Civ. P. 12(b)(6).” Sumner v. Tucker, 9 F. Supp. 2d 641, 642 (E.D. Va. 1998). Accordingly, a plaintiff's alleged facts are presumed true, and the complaint should be dismissed only when “‘it is clear that no relief could be granted under any set of facts that could be proved consistent with the allegations.” Hishon v. King & Spalding, 467 U.S. 69, 73 (1984). To survive a 12(b)(6) motion, “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 Atlantic Corp. v. Twombly, 550 U.S. 544, 570 (2007)). A claim is facially plausible when “the plaintiff pleads factual content that allows the court to draw the reasonable inference that the defendant is liable for the misconduct alleged.” Id. A plaintiff's allegations must “raise a right to relief above the speculative level,” and “threadbare recitals of the elements of a cause of action, supported by mere conclusory statements, do not suffice” to meet this standard. Id. Where a complaint is filed by a prisoner acting pro se, however, that complaint must be construed liberally regardless of how unskillfully it is pleaded. Haines v. Kerner, 404 U.S. 519, (1972). A pro se litigant is therefore not held to the strict pleading requirements demanded of attorneys. Estelle v. Gamble, 429 U.S. 97, 106-07 (1976); Figgins v. Hudspeth, 584 F.2d 1345 (4th Cir. 1978), cert. denied, 441 U.S. 913 (1979). III. Analysis Liberally construing the second amended complaint and construing it in the light most favorable to plaintiff, Porter alleges that Defendant Harris was the Head of the medical unit on October 31, 2019 when he was initially treated for the stab wound to his face. [Dkt. No. 20 at 3]. Plaintiff makes no allegation that Harris treated his injury or that he had any interaction or

knowledge of the injury. At best, plaintiff is alleging a supervisory liability claim for an Eighth Amendment violation because Harris was in charge of the medical unit on the day he was treated for the injury. An Eighth Amendment claim for denial of medical care must allege facts sufficient to show that jail officials were deliberately indifferent to a serious medical need. Estelle, 429 U.S. at 105; Staples v. Va. Dep’t of Corr., 904 F. Supp. 487, 492 (E.D. Va. 1995). Thus, plaintiff must allege two distinct elements to state a claim upon which relief can be granted. First, he must allege a sufficiently serious medical need. See, e.g., Cooper v. Dyke, 814 F.2d 941, 945 (4th Cir. 1987) (determining that intense pain from an untreated bullet wound is sufficiently serious); Loe v. Armistead, 582 F.2d 1291, 1296 (4th Cir. 1978) (concluding that the “excruciating pain” of an untreated broken arm is sufficiently serious). A serious medical need is one that poses a substantial risk of serious injury to an inmate’s health and safety. Young v. City of Mt. Ranier, 238 F.3d 567, 576 (4th Cir. 2001). Second, he must allege deliberate indifference to that serious medical need. Under this second prong, an assertion of mere negligence or even malpractice is not enough to state an Eighth Amendment violation; instead, plaintiff must allege deliberate indifference “by either actual intent or reckless disregard.” Estelle, 429 U.S. at 106; Daniels v.

Free access — add to your briefcase to read the full text and ask questions with AI

Related

Mann v. Taser International, Inc.
588 F.3d 1291 (Eleventh Circuit, 2009)
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)
Hishon v. King & Spalding
467 U.S. 69 (Supreme Court, 1984)
Daniels v. Williams
474 U.S. 327 (Supreme Court, 1986)
Davidson v. Cannon
474 U.S. 344 (Supreme Court, 1986)
Bell Atlantic Corp. v. Twombly
550 U.S. 544 (Supreme Court, 2007)
Ashcroft v. Iqbal
556 U.S. 662 (Supreme Court, 2009)
Warren Phillips Pink v. L.T. Lester P.J. Gurney
52 F.3d 73 (Fourth Circuit, 1995)
David Evans v. Patrick Baker
703 F.3d 636 (Fourth Circuit, 2012)
Harris v. Murray
761 F. Supp. 409 (E.D. Virginia, 1990)
Staples v. Virginia Department of Corrections
904 F. Supp. 487 (E.D. Virginia, 1995)

Cite This Page — Counsel Stack

Bluebook (online)
Porter v. Hamilton, Counsel Stack Legal Research, https://law.counselstack.com/opinion/porter-v-hamilton-vaed-2022.