Pulley v. Zoley

District Court, E.D. Virginia·Decided November 20, 2024·No. 1:23-cv-00846·Unknown

Opinion

IN THE UNITED STATES DISTRICT COURT FOR THE EASTERN DISTRICT OF VIRGINIA Alexandria Division JASON PULLEY, ) Plaintiff, ) ) v. ) 1:23cv846 (RDA/JFA) ) GEORGE ZOLEY, et al., ) Defendants. ) MEMORANDUM OPINION AND ORDER Jason Pulley (“Pulley” or “Plaintiff’), a Virginia inmate proceeding pro se, filed a civil rights action under 42 U.S.C. § 1983. Dkt. No. 1. In his Complaint, Pulley alleged that George Zoley and Harold W. Clarke (collectively, the “Defendants”) violated his Eighth Amendment rights on October 13, 2022, while he was detained at the Virginia Department of Corrections’ (“VDOC”) Lawrenceville Correctional Center (“Lawrenceville”). Specifically, Plaintiff alleges that Defendants failed to protect him from an attack by another inmate due to a faulty lock on Pulley’s cell door and inadequate supervision. /d. at 5-6. Defendant Clake moved to dismiss, or in the alternative moved for summary judgment. Dkt. No. 17. Defendant Zoley moved to dismiss. Dkt. No. 20. Plaintiff filed responsive materials and pleadings pursuant to Roseboro v. Garrison, 528 F.2d 309 (4th Cir. 1975).'! Dkt. Nos. 22, 24, 25. On August 20, 2024, the Court granted Defendants Clarke’s and Zoley’s motions to dismiss, dismissed Defendant Clarke’s motion for summary judgment as moot, and denied

' The Court notes that in compliance with Local Rule 7(K), Defendants provided Plaintiff with the notice required pursuant to Roseboro v. Garrison, 528 F.2d 309 (4th Cir. 1975). See Dkt. 7. Arecent 4th Circuit decision, Milla v. Brown, 109 F.4th 222 (4th Cir. 2024), has cast doubt on whether Local Rule 7(K) satisfies Roseboro, and a revised Rule 7(K) has been proposed accordingly. This Court notes that Plaintiff responded to Defendants’ Motions to Dismiss as set forth in Defendants’ Roseboro notices, see Dkts. 24; 25, and therefore the Court does not view the Milla decision as an impediment to this Court issuing this order.

Pulley’s motion to dismiss Defendant Clarke’s motion for summary judgment as moot.” See Dkt. 38. In that Order, the Court granted Pulley leave to amend his complaint to cure the deficiencies noted in the Opinion within thirty (30) days. Dkt. No. 37 at 9. The time to file an amended complaint has long passed, and accordingly, the Court will dismiss this matter with prejudice. The Court’s August 20, 2024 Memorandum Opinion recognized that the Eighth Amendment imposes duties on prison officials to take reasonable measures to guarantee the safety of inmates and to ensure that inmates receive adequate food, clothing, shelter, and medical care, Farmer v. Brennan, 511 U.S. 825, 832 (1994), and that to state a colorable claim for the violation of these duties, the prisoner must show that prison officials were deliberately indifferent to serious threats to his safety, id. at 834, and show that a prison official was deliberately indifferent to a serious threat to the prisoner’s safety by pleading that “the official [knew] of and disregard[ed] an excessive risk to inmate... safety.” /d. at 837. “[T]he official must both be aware of facts from which the inference could be drawn that a substantial risk of serious harm exists, and [the official] must also draw the inference.” /d. (emphasis added). Further, prison officials may not escape liability because they cannot, or did not, identify the specific source of the risk; the serious threat can be one to which all prisoners are exposed. /d. at 843. It is generally understood that “prisons are dangerous places. Inmates get there by violent acts, and many prisoners have a propensity to commit more.” Riccardo v. Rausch, 375 F.3d 521, 525 (7th Cir. 2004). “Any time an individual is incarcerated, there is some risk that he may be a victim of violence at the hands of fellow inmates... .” Westmoreland v. Brown, 883 F. Supp. 67, 74 (E.D. Va. 1995). Accordingly, a baseline risk of assault inherent to prison life cannot support

2 Defendant Clarke’s and Defendant Zoley’s motion to dismiss cited Federal Rule of Civil Procedure 12(b)(6), which permits a defendant to seek dismissal of a complaint based upon a plaintiff's “failure to state a claim upon which relief can be granted.” Fed. R. Civ. P. 12 (b)(6).

an Eighth Amendment claim, see Grieveson v. Anderson, 538 F.3d 763, 776-77 (7th Cir. 2008), and a general risk of violence in prison does not by itself establish that a defendant actually knew about a serious risk of harm. See Shields v. Dart, 664 F.3d 178, 181 (7th Cir. 2011); Dale, 548 F.3d at 569. Accordingly, a defendant cannot be held liable simply because he knew of a “mere possibility” violence would occur. A defendant had to have been alerted to the fact there was a “strong likelihood” of harm. See Pinkston v. Madry, 440 F.3d 879, 889 (7th Cir. 2006). In addition, when evaluating a claim based upon assault by another inmate, the Fourth Circuit has interpreted Farmer’s deliberate indifference standard to require that a prison official must have both “subjectively recognized a substantial risk of harm” and “subjectively recognized that his actions were ‘inappropriate in light of that risk.’” [Parrish ex rel. Lee v. Cleveland, 372 F.3d 294,] 303 [(4th Cir. 2004)] (emphasis added) (quoting Rich v. Bruce, 129 F.3d 336, 340 n.2 (4th Cir. 1997) (“True subjective recklessness requires knowledge both of the general risk, and also that the conduct is inappropriate in light of that risk”)); see also Cox [v. Quinn], 828 F.3d [227,] 236 [(4th Cir. 2016)] (“[I]n addition to subjectively recognizing that substantial risk, the prison official must also subjectively be aware that ‘his actions were inappropriate in light of that risk’”). Anderson y. Kingsley, 877 F.3d 539, 545 (4th Cir. 2017). defendant is not subjectively reckless where, although he is aware of the existence of a general risk, he is unaware that his conduct is inappropriate in light of that risk.” Rich, 129 F.3d at 340; see Makdessi v. Fields, 789 F.3d 126, 133 (4th Cir. 2015) (“‘not every injury suffered by a prisoner at the hands of another translates into constitutional liability for prison officials responsible for the victim’s safety.’”) (quoting Farmer, 511 U.S. at 832). In addition, while a supervisor can be held liable for the constitutional injuries inflicted by their subordinates under some circumstances, “[I]iability in this context is not premised on respondeat superior, Monell v. Department of Social Services, 436 U.S. 658

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