Rivers v. United States

CourtDistrict Court, W.D. North Carolina
DecidedJanuary 21, 2025
Docket5:24-cv-00157
StatusUnknown

This text of Rivers v. United States (Rivers v. United States) 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
Rivers v. United States, (W.D.N.C. 2025).

Opinion

UNITED STATES DISTRICT COURT WESTERN DISTRICT OF NORTH CAROLINA STATESVILLE DIVISION 5:24-cv-157-KDB

MAURICE D. RIVERS, ) ) Plaintiff, ) ) vs. ) ) UNITED STATES, et al., ) ORDER ) Defendants. ) ___________________________________ )

THIS MATTER is before the Court on initial review of the pro se Amended Complaint [Doc. 13]. The Plaintiff is proceeding in forma pauperis. [Doc. 8]. I. BACKGROUND The pro se Plaintiff filed this action while he was a pretrial detainee at the Iredell County Jail.1 The Court dismissed the Complaint on initial review and granted Plaintiff the opportunity to file a superseding Amended Complaint. [Doc. 10]. The Amended Complaint is now before the Court for initial review. [Doc. 13]. The Plaintiff asserts claims under 42 U.S.C. § 1983 and Bivens v. Six Unknown Named Agents of the Federal Bureau of Narcotics, 403 U.S. 388 (1971), the Universal Declaration of Human Rights, the Americans with Disabilities Act (“ADA”), and several provisions of North Carolina law including N.C. Gen. Stat. §§ 78-101(a)(1) and 90-87(13). [Doc. 13 at 3, 22]. The Plaintiff names as Defendants, in their official capacities: the United States; Youth Focus Psychiatric Hospital; the federal Department of Health and Human Services (“DHHS”); the North

1 The Plaintiff is presently a prisoner of the State of North Carolina at the Piedmont Correctional Institution. Carolina Department of Social Services (“DSS”); the DSS Director; and Kamala Harris. [Doc. 13 at 1-3]. The Plaintiff again argues inter alia that childhood abuse and the administration of psychotropic medications at a psychiatric hospital in 1993 and 1994 while he was a minor rendered him a disabled “drug dependent person” who requires treatment, and who should not be held

responsible for his criminal actions. [Id. at 12, 18-20]. He seeks damages; disabled status as of 1993; “full compensation” including a housing voucher for land in the North Carolina mountains; a Chevy Silverado; and expungement of his criminal record. [Id. at 20-21]. II. STANDARD OF REVIEW Because the Plaintiff is proceeding in forma pauperis, the Court must review the Amended Complaint to determine whether it is subject to dismissal on the grounds that it is “frivolous or malicious [or] fails to state a claim on which relief may be granted.” 28 U.S.C. § 1915(e)(2). Furthermore, under § 1915A 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 a 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 by a “person” acting under color of state law. See 42 U.S.C. § 1983; Am. Mfrs. Mut. Ins. Co. v. Sullivan, 526 U.S. 40, 49-50 (1999); Health & Hosp. Corp. of Marion Cnty. v. Talevski, 599 U.S.

166 (2023). To satisfy the state action requirement, a plaintiff must demonstrate that the conduct at issue is “fairly attributable to the State.” Lugar v. Edmondson Oil Co., 457 U.S. 922, 937 (1982). If the defendant is not a state actor, there must be a “sufficiently close relationship with state actors such that a court would conclude that the non-state actor is engaged in the state’s actions.” DeBauche v. Trani, 191 F.3d 499, 506 (4th Cir. 1999). A private company is liable under § 1983 “only when an official policy or custom of the corporation causes the alleged deprivation of federal rights.” Austin v. Paramount Parks, Inc., 195 F.3d 715, 728 (4th Cir. 1999) (citations omitted); see Monell v. Dep’t of Social Servs., 436 U.S. 658, 690 (1978). Section 1983 liability cannot be based solely on a theory of respondeat superior. Id.

To establish liability under 42 U.S.C. § 1983, a plaintiff “must affirmatively show that the official charged acted personally in the deprivation of [his] rights.” Williamson v. Stirling, 912 F.3d 154, 171 (4th Cir. 2018) (cleaned up); see Vinnedge v. Gibbs, 550 F.2d 926, 928 (4th Cir. 1977) (citation omitted). “[N]either a state nor its officials acting in their official capacities are ‘persons’ under § 1983.” Will v. Michigan Dep’t of State Police, 491 U.S. 58, 71 (1989). Moreover, the Eleventh Amendment generally bars lawsuits by citizens against non-consenting states brought either in state or federal courts. See Alden v. Maine, 527 U.S. 706, 712-13 (1999); Seminole Tribe of Florida v. Florida, 517 U.S. 44, 54 (1996). Although Congress may abrogate the states’ sovereign immunity, it has not chosen to do so for claims under 42 U.S.C. § 1983. See Quern v. Jordan, 440 U.S. 332, 343 (1979). Likewise, North Carolina has not waived its sovereign immunity by consenting to be sued in federal court for claims brought under 42 U.S.C. § 1983. See generally Mary’s House, Inc. v. North Carolina, 976 F.Supp.2d 691, 697 (M.D.N.C. 2013) (claim under 42 U.S.C. § 1983 barred by sovereign immunity of North Carolina). A Bivens action is the judicially-created counterpart to 42 U.S.C. § 1983, and allows an

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

Related

Haines v. Kerner
404 U.S. 519 (Supreme Court, 1972)
Monell v. New York City Dept. of Social Servs.
436 U.S. 658 (Supreme Court, 1978)
Quern v. Jordan
440 U.S. 332 (Supreme Court, 1979)
Lugar v. Edmondson Oil Co.
457 U.S. 922 (Supreme Court, 1982)
Neitzke v. Williams
490 U.S. 319 (Supreme Court, 1989)
Will v. Michigan Department of State Police
491 U.S. 58 (Supreme Court, 1989)
Denton v. Hernandez
504 U.S. 25 (Supreme Court, 1992)
Federal Deposit Insurance v. Meyer
510 U.S. 471 (Supreme Court, 1994)
Seminole Tribe of Florida v. Florida
517 U.S. 44 (Supreme Court, 1996)
Alden v. Maine
527 U.S. 706 (Supreme Court, 1999)
Correctional Services Corp. v. Malesko
534 U.S. 61 (Supreme Court, 2001)
Ashcroft v. Iqbal
556 U.S. 662 (Supreme Court, 2009)
United States v. Benabe
654 F.3d 753 (Seventh Circuit, 2011)
United States v. Lanaire White
480 F. App'x 193 (Fourth Circuit, 2012)
McLean v. United States
566 F.3d 391 (Fourth Circuit, 2009)
DeBauche v. Trani
191 F.3d 499 (Fourth Circuit, 1999)

Cite This Page — Counsel Stack

Bluebook (online)
Rivers v. United States, Counsel Stack Legal Research, https://law.counselstack.com/opinion/rivers-v-united-states-ncwd-2025.