Scanlan v. Bonner

CourtDistrict Court, W.D. Tennessee
DecidedJanuary 2, 2025
Docket2:22-cv-02023
StatusUnknown

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

Bluebook
Scanlan v. Bonner, (W.D. Tenn. 2025).

Opinion

IN THE UNITED STATES DISTRICT COURT FOR THE WESTERN DISTRICT OF TENNESSEE WESTERN DIVISION

) MICHAEL ANTHONY SCANLAN, ) ) Plaintiff, ) ) v. ) Case No. 2:22-cv-2023-SHM-tmp ) FLOYD BONNER, et al., ) ) Defendants. ) )

ORDER DISMISSING CASE WITHOUT PREJUDICE AND GRANTING LEAVE TO AMEND

On January 14, 2022, Plaintiff Michael Anthony Scanlan, booking number 21110794, who was then incarcerated at the Shelby County Criminal Justice Center (“SCJC”) in Memphis, Tennessee, filed a pro se civil complaint and a motion to proceed in forma pauperis. (ECF Nos. 1 & 2.) On January 21, 2022, the Court granted leave to proceed in forma pauperis and assessed the filing fee under the Prison Litigation Reform Act (“PLRA”), 28 U.S.C. § 1914, et seq. (ECF No. 4.) The Complaint is construed to allege claims of unconstitutional conditions of confinement. Plaintiff alleges that, while in custody from August 11, 2021 until January 5, 2022, Plaintiff was “never given an opportunity” for recreation and that the “[f]acility has allowed other inmates to have physical [r]ecreation inside and outside of this [f]acility.” (ECF No. 1 at PageID 18.) Plaintiff alleges that he has spent most of his time in solitary confinement. (Id.) Plaintiff sues the following Defendants: (1) Floyd Bonner; (2) Kirk Fields; and (3) the Shelby County Sheriff’s Department. (Id. at PageID 17-18.) Plaintiff requests two hundred thousand dollars ($200,000.00) in “monetary” and punitive damages. (Id. at PageID 19.) The Complaint (ECF No. 1) is before the Court for screening.

For the reasons explained below: (1) the Complaint (ECF No. 1) is DISMISSED WITHOUT PREJUDICE; and (2) leave to amend the Complaint is GRANTED. I. LEGAL STANDARD

The Court is required to screen prisoner complaints and to dismiss any complaint, or any portion thereof, if the complaint— (1) is frivolous, malicious, or fails to state a claim upon which relief may be granted; or

(2) seeks monetary relief from a defendant who is immune from such relief.

28 U.S.C. § 1915A(b); see also 28 U.S.C. § 1915(e)(2)(B). In assessing whether the complaint states a claim on which relief may be granted, the Court applies the standards under Fed. R. Civ. P. 12(b)(6), as stated in Ashcroft v. Iqbal, 556 U.S. 662, 677-79 (2009), and in Bell Atl. Corp. v. Twombly, 550 U.S. 544, 555-57 (2007); see Hill v. Lappin, 630 F.3d 468, 470-71 (6th Cir. 2010). Under those standards, the Court accepts as true the complaint’s “well-pleaded” factual allegations and then determines whether the allegations “plausibly suggest an entitlement to relief.” Williams v. Curtin, 631 F.3d 380, 383 (6th Cir. 2011) (quoting Iqbal, 556 U.S. at 681, 129 S. Ct. at 1951). “[P]leadings that . . . are no more than conclusions are not entitled to the assumption of truth. While legal conclusions can provide the framework of a complaint, they must be supported by factual allegations.” Iqbal, 556 U.S. at 679, 129 S. Ct. at 1950. Federal Rule of Civil Procedure 8 provides guidance on this issue. Although Rule 8 requires a complaint to contain “a short and plain statement of the claim showing that the pleader is entitled to relief,” it also requires factual allegations to make a “‘showing,’ rather than a blanket assertion, of entitlement to relief.” Twombly, 550 U.S. at 555 n.3. Courts screening cases accord more deference to pro se complaints than to those drafted by lawyers. “Pro se complaints are to be held ‘to less stringent standards than formal pleadings

drafted by lawyers,’ and should therefore be liberally construed.” Williams, 631 F.3d at 383 (quoting Martin v. Overton, 391 F.3d 710, 712 (6th Cir. 2004)). Pro se litigants are not exempt from the requirements of the Federal Rules of Civil Procedure. Wells v. Brown, 891 F.2d 591, 594 (6th Cir. 1989); see also Brown v. Matauszak, 415 F. App’x 608, 612, 613 (6th Cir. 2011) (affirming dismissal of pro se complaint because “a court cannot ‘create a claim which [a plaintiff] has not spelled out in his pleading’” (quoting Clark v. Nat’l Travelers Life Ins. Co., 518 F.2d 1167, 1169 (6th Cir. 1975))); Payne v. Sec’y of Treasury, 73 F. App’x 836, 837 (6th Cir. 2003) (affirming sua sponte dismissal of complaint pursuant to Fed. R. Civ. P. 8(a)(2) and stating that “[n]either this court nor the district court is required to create [Plaintiff]’s claim for her”); cf. Pliler v. Ford, 542 U.S. 225, 231 (2004) (“District judges have no obligation to act as counsel or paralegal to pro

se litigants”). II. REQUIREMENTS TO STATE A CLAIM UNDER § 1983

Plaintiff sues under 42 U.S.C. § 1983. (ECF No. 1 at PageID 17.) To state a claim under § 1983, a plaintiff must allege two elements: (1) a deprivation of rights secured by the “Constitution and laws” of the United States, and (2) that a defendant caused harm while acting under color of state law. Adickes v. S.H. Kress & Co., 398 U.S. 144, 150 (1970). For the reasons explained below, Plaintiff fails to allege sufficient facts demonstrating a claim to relief under § 1983. III. ANALYSIS

A. Shelby County Sheriff’s Department It is well-established in the Sixth Circuit that a police department is not a proper defendant in a § 1983 action. See Matthews v. Jones, 35 F.3d 1046, 1049 (6th Cir. 1994) (“[T]he Police Department is not an entity which may be sued”). “[S]ince Matthews, federal district courts in Tennessee have frequently and uniformly held that police departments and sheriff’s departments are not proper parties to a § 1983 suit.” Mathes v. Metro Gov’t of Nashville & Davidson Cnty., No. 3:10-CV-0496, 2010 WL 3341889, at *2 (M.D. Tenn., Aug. 25, 2010); see Grace v. City of Ripley, Tennessee, No. 2:16-cv-02395-JPM-dkv, 2017 WL 835206, at *5 (W.D. Tenn. Mar. 2, 2017) (same). Sheriff's departments can properly be characterized as “sub-units of the municipalities they serve.” Sargent v. City of Toledo Police Dep’t, 150 F. App’x 470, 475 (6th Cir. 2005); accord Kindle v. City of Jeffersontown, Ky., 374 F. App’x 562, 570 (6th Cir. 2010); Duck v. Madison Cnty. Sheriff’s Dep’t, No. 1:17-CV-01043-JDB-egb, 2018 WL 2966950, at *3 (W.D. Tenn. June

13, 2018) (citing cases). Plaintiff has failed to state a claim against the Shelby County Sheriff’s Department. B. Bonner & Fields Plaintiff does not specify whether he is suing the Defendants in their official or individual capacities.

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Bluebook (online)
Scanlan v. Bonner, Counsel Stack Legal Research, https://law.counselstack.com/opinion/scanlan-v-bonner-tnwd-2025.