Sheriff v. Rule

CourtDistrict Court, D. Connecticut
DecidedMay 1, 2023
Docket3:22-cv-01479
StatusUnknown

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

Bluebook
Sheriff v. Rule, (D. Conn. 2023).

Opinion

UNITED STATES DISTRICT COURT DISTRICT OF CONNECTICUT

: BRYAN SHERIFF, : Plaintiff, : : v. : No. 3:22cv1479 (MPS) : LIEUTENANT RULE, et al., : Defendants. : :

INITIAL REVIEW ORDER

Plaintiff Bryan Sheriff, an inmate in the custody of the Department of Correction (“DOC”), has filed his complaint in this action pro se under 42 U.S.C. § 1983.1 Compl., ECF No. 1.2 He names as defendants four DOC employees who work at MacDougall-Walker Correctional Institution: Lieutenant Rule, Correction Officers John and Jane Doe, and Nurse Jane Doe. The Court construes his complaint as alleging Eighth Amendment violations against Defendants in their individual capacities for damages.3 The Prison Litigation Reform Act requires that federal courts review complaints brought by prisoners seeking relief against a governmental entity or officer or employee of a governmental entity. 28 U.S.C. § 1915A(a). Upon review, the Court must dismiss the complaint,

1 The Court may “take judicial notice of relevant matters of public record.” See Giraldo v. Kessler, 694 F.3d 161, 164 (2d Cir. 2012). The publicly available information on the judicial branch website shows that Sheriff was sentenced on October 24, 2019 for a criminal conviction to a term of incarceration, with its execution suspended after 18 months, probation for three years. After he was found guilty of a probation violation, his probation was terminated on August 17, 2022. See Case Detail for HHD -CR18-0699855-T at https://www.jud2.ct.gov/crdockets/SearchByDefDisp.aspx.

2 Plaintiff paid the filing fee on January 24, 2023.

3 To the extent Plaintiff seeks monetary damages against Defendants, who are state employees, in their official capacities, such claims are barred by the Eleventh Amendment. See, e.g., Kentucky v. Graham, 473 U.S. 159, 169 (1985). or any portion of the complaint, that 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. 28 U.S.C. §§ 1915(e)(2)(B), 1915A(b). The Court has thoroughly reviewed all factual allegations in the complaint and conducted

an initial review of the allegations therein pursuant to 28 U.S.C. §1915A. I. Allegations The Court does not include herein all of the allegations from the complaint but summarizes the facts to provide a context to this initial review. Plaintiff is paralyzed from the chest down due to a spinal cord injury and is in a wheelchair. He requires a catheter to use the bathroom. At 5:30 PM on November 25, 2019, Plaintiff pressed the emergency medical button to notify Officer Jane Doe that he needed his medical supplies so that he could use the bathroom. After Officer Jane Doe ignored his medical button call, Plaintiff attempted to gain her attention by knocking on his cell door as his cell was directly across from her desk.

Correction Officer Jane Doe called Lieutenant Rule, who arrived at Plaintiff’s cell with a team of correction officers. Lieutenant Rule informed Plaintiff that he would be sent to the Restricted Housing Unit (“RHU”) as punishment for knocking on his door and calling out for a correction officer. Plaintiff did not pose any resistance. He began to roll out of his wheelchair when Defendant Rule grabbed his legs and pulled him to the ground. Plaintiff cried and screamed out that he was a paraplegic who could not use his legs. Defendant Rule tried to roll Plaintiff over onto his stomach, but Plaintiff’s upper body twisted differently than his lower body. Defendant Rule put his knee into Plaintiff’s back while he handcuffed Plaintiff’s hands behind his back. He told Officer Jane Doe that she could start the recording after Plaintiff was handcuffed and placed back into his wheelchair. At the RHU, Plaintiff was strip searched and placed in a cell where he discovered that his knees were swollen, he felt a sharp pain in his hips, and he felt “out of place” due to being

“twisted up” on the floor. He told Defendant Rule that he needed to see a doctor. Shortly thereafter, he told Nurse Jane Doe about his excruciating pain in his lower back, hips and knees and requested to have an X-ray taken. She provided him with pain medication and told him that he should not be experiencing pain if he is paralyzed. She advised him to sign up for sick call in five days after his RHU release. After he was released, Plaintiff wrote to sick call requesting to see a doctor and have an X-ray. He never received a response. He continues to experience lower back pain and his knees are crooked when he extends them. He claims that Defendants’ conduct exacerbated his spinal cord injury. II. Discussion

The Court construes Plaintiff’s complaint as asserting Eighth Amendment excessive force and deliberate indifference claims against Defendants. A. Personal Involvement A plaintiff seeking monetary damages from a defendant must allege facts that establish the personal involvement of that defendant in the alleged constitutional violation. See Wright v. Smith, 21 F.3d 496, 501 (2d Cir. 1994) (“It is well settled in this Circuit that ‘personal involvement of defendants in alleged constitutional deprivations is a prerequisite to an award of damages under § 1983.’” (quoting Moffitt v. Town of Brookfield, 950 F.2d 880, 886 (2d Cir. 1991))). To “hold a state official liable under § 1983, a plaintiff must plead and prove the elements of the underlying constitutional violation directly against the official without relying on a special test for supervisory liability.” Tangreti v. Bachman, 983 F.3d 609, 620 (2d Cir. 2020). Plaintiff’s complaint contains no factual allegations describing any conduct by Correction Officer John Doe. Accordingly, the Court must dismiss any claim against Officer John Doe

because no facts in the complaint suggest his involvement in a constitutional violation. B. Eighth Amendment Excessive Force In order to adequately allege an Eighth Amendment claim of excessive force, Plaintiff must show that the force employed by a defendant was not “applied in a good-faith effort to maintain or restore discipline” but was done “maliciously or sadistically to cause harm,” and that the harm done was objectively serious enough to violate Plaintiff's constitutional right to be free from such harm. See Sims v. Artuz, 230 F.3d 14, 21 (2d Cir. 2000). For purposes of initial review, Plaintiff has alleged facts that plausibly suggest that Lieutenant Rule’s conduct to pull him out of his wheelchair, roll him over, handcuff him behind his back and place him in segregation in the RHU was objectively unreasonable and done in order to maliciously or

sadistically cause Plaintiff harm. Accordingly, Plaintiff may proceed on his Eighth Amendment excessive force claim against Lieutenant Rule in his individual capacity. C.

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Related

Kentucky v. Graham
473 U.S. 159 (Supreme Court, 1985)
Moffitt v. Town Of Brookfield
950 F.2d 880 (Second Circuit, 1991)
Hill v. Curcione
657 F.3d 116 (Second Circuit, 2011)
Sims v. Artuz
230 F.3d 14 (Second Circuit, 2000)
Morgan v. Dzurenda
956 F.3d 84 (Second Circuit, 2020)
Tangreti v. Bachmann
983 F.3d 609 (Second Circuit, 2020)
Salahuddin v. Goord
467 F.3d 263 (Second Circuit, 2006)
Giraldo v. Kessler
694 F.3d 161 (Second Circuit, 2012)
Washington v. Artus
708 F. App'x 705 (Second Circuit, 2017)

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Bluebook (online)
Sheriff v. Rule, Counsel Stack Legal Research, https://law.counselstack.com/opinion/sheriff-v-rule-ctd-2023.