Reid v. Campbell

CourtDistrict Court, W.D. Kentucky
DecidedJune 28, 2024
Docket5:24-cv-00064
StatusUnknown

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

Bluebook
Reid v. Campbell, (W.D. Ky. 2024).

Opinion

UNITED STATES DISTRICT COURT WESTERN DISTRICT OF KENTUCKY PADUCAH DIVISION

MICHAEL SHANE REID PLAINTIFF

v. CIVIL ACTION NO. 5:24-CV-P64-JHM

WESLEY CAMPBELL DEFENDANT

MEMORANDUM OPINION AND ORDER

This is a pro se 42 U.S.C. § 1983 prisoner civil-rights action. This matter is before the Court for screening pursuant to 28 U.S.C. § 1915A. For the reasons set forth below, the Court dismiss some claims and allow one claim to proceed. I. Plaintiff Michael Shane Reid is incarcerated as a convicted prisoner at Christian County Jail (CCJ). Plaintiff sues CCJ Captain Wesley Campbell in both his official and individual capacities. Plaintiff states that he was transferred to CCJ “as a state inmate with a custody level of 1 to be placed to work.” He alleges that Defendant Campbell informed him that “he could not put me to work . . . because it was against policy to work inmates with holds.” Plaintiff states that he contacted the Kentucky Department of Corrections (KDOC) and was told that no such policy exists. Plaintiff also alleges that several other inmates with “holds” are working at CCJ. Plaintiff states that when he asked the CCJ Jailer about his situation, the Jailer told him that “it’s up to Captain Campbell whether he wants to work [you] or not.” Plaintiff alleges that Defendant Campbell is discriminating against him because “I am not local and not known.” Plaintiff states that Defendant Campbell’s refusal to allow him to work is adversely affecting his ability to earn “good time” and state pay. As relief, he seeks damages. II. Because Plaintiff is a prisoner seeking relief against governmental entities, officers, and/or employees, this Court must review the instant action under 28 U.S.C. § 1915A. Under § 1915A, the trial court must review the complaint and dismiss the complaint, or any portion of the

complaint, if the court determines that it is frivolous or malicious, fails to state a claim upon which relief may be granted, or seeks monetary relief from a defendant who is immune from such relief. See § 1915A(b)(1), (2); and McGore v. Wrigglesworth, 114 F.3d 601, 604 (6th Cir. 1997), overruled on other grounds by Jones v. Bock, 549 U.S. 199 (2007). In order to survive dismissal for failure to state a claim, “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 Atl. Corp. v. Twombly, 550 U.S. 544, 570 (2007)). “[A] district court must (1) view the complaint in the light most favorable to the plaintiff and (2) take all well-pleaded factual allegations as true.” Tackett v. M & G Polymers, USA, LLC,

561 F.3d 478, 488 (6th Cir. 2009) (citing Gunasekera v. Irwin, 551 F.3d 461, 466 (6th Cir. 2009) (citations omitted)). “[A] pro se complaint, however inartfully pleaded, must be held to less stringent standards than formal pleadings drafted by lawyers.” Erickson v. Pardus, 551 U.S. 89 (2007) (quoting Estelle v. Gamble, 429 U.S. 97, 106 (1976)). However, while liberal, this standard of review does require more than the bare assertion of legal conclusions. See Columbia Natural Res., Inc. v. Tatum, 58 F.3d 1101, 1109 (6th Cir. 1995). The Court’s duty “does not require [it] to conjure up unpled allegations,” McDonald v. Hall, 610 F.2d 16, 19 (1st Cir. 1979), or to create a claim for Plaintiff. Clark v. Nat’l Travelers Life Ins. Co., 518 F.2d 1167, 1169 (6th Cir. 1975). To command otherwise would require the court “to explore exhaustively all potential claims of a pro se plaintiff, [and] would also transform the district court from its legitimate advisory role to the improper role of an advocate seeking out the strongest arguments and most successful strategies for a party.” Beaudett v. City of Hampton, 775 F.2d 1274, 1278 (4th Cir. 1985). III. “Section 1983 creates no substantive rights, but merely provides remedies for deprivations

of rights established elsewhere.” Flint ex rel. Flint v. Ky. Dep’t of Corr., 270 F.3d 340, 351 (6th Cir. 2001). Two elements are required to state a claim under § 1983. Gomez v. Toledo, 446 U.S. 635 (1980). “[A] plaintiff must allege the violation of a right secured by the Constitution and laws of the United States, and must show that the alleged deprivation was committed by a person acting under color of state law.” West v. Atkins, 487 U.S. 42, 48 (1988). “Absent either element, a section 1983 claim will not lie.” Christy v. Randlett, 932 F.2d 502, 504 (6th Cir. 1991). A. Official-Capacity Claim “Official-capacity suits . . . ‘generally represent [] another way of pleading an action against an entity of which an officer is an agent.’” Kentucky v. Graham, 473 U.S. 159, 166 (1985) (quoting

Monell v. Dep’t of Soc. Servs. of N.Y., 436 U.S. 658, 691 n.55 (1978)). Thus, Plaintiff’s official- capacity claim against Defendant Campbell is actually against his employer, Christian County. A municipality such as Christian County cannot be held responsible for a constitutional deprivation unless there is a direct causal link between a policy or custom of the municipality and the alleged constitutional deprivation. Monell, 436 U.S. at 691 (1978); Deaton v. Montgomery Cnty., Ohio, 989 F.2d 885, 889 (6th Cir. 1993). The policy or custom “must be ‘the moving force of the constitutional violation’ in order to establish the liability” of the municipality under § 1983. Searcy v. City of Dayton, 38 F.3d 282, 286 (6th Cir. 1994) (quoting Polk Cnty. v. Dodson, 454 U.S. 312, 326 (1981) (citation omitted)). In the instant case, Plaintiff states that he was told by the CCJ Jailer that Defendant Campbell’s decisions regarding which inmates could work were not based upon any CCJ policy but Defendant Campbell’s discretion. Thus, Plaintiff’s official-capacity claim against Defendant Campbell must be dismissed for failure to state a claim upon which relief may be granted. B. Individual-Capacity Claims

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Related

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)
Gomez v. Toledo
446 U.S. 635 (Supreme Court, 1980)
Polk County v. Dodson
454 U.S. 312 (Supreme Court, 1981)
Kentucky v. Graham
473 U.S. 159 (Supreme Court, 1985)
West v. Atkins
487 U.S. 42 (Supreme Court, 1988)
Erickson v. Pardus
551 U.S. 89 (Supreme Court, 2007)
Bell Atlantic Corp. v. Twombly
550 U.S. 544 (Supreme Court, 2007)
Jones v. Bock
549 U.S. 199 (Supreme Court, 2007)
Ashcroft v. Iqbal
556 U.S. 662 (Supreme Court, 2009)
Anthony F. McDonald v. Frank A. Hall
610 F.2d 16 (First Circuit, 1979)
Karen Christy v. James R. Randlett
932 F.2d 502 (Sixth Circuit, 1991)
Elaine Deaton v. Montgomery County, Ohio
989 F.2d 885 (Sixth Circuit, 1993)
Davis v. Prison Health Services
679 F.3d 433 (Sixth Circuit, 2012)

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Bluebook (online)
Reid v. Campbell, Counsel Stack Legal Research, https://law.counselstack.com/opinion/reid-v-campbell-kywd-2024.