Smith v. Harris County Sheriff's Officer Reyes

CourtDistrict Court, S.D. Texas
DecidedNovember 26, 2024
Docket4:24-cv-01839
StatusUnknown

This text of Smith v. Harris County Sheriff's Officer Reyes (Smith v. Harris County Sheriff's Officer Reyes) is published on Counsel Stack Legal Research, covering District Court, S.D. Texas primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Smith v. Harris County Sheriff's Officer Reyes, (S.D. Tex. 2024).

Opinion

IN THE UNITED STATES DISTRICT COURT November 26, 2024 FOR THE SOUTHERN DISTRICT OF TEXAS Nathan Ochsner, Clerk HOUSTON DIVISION

SCOTT SMITH, § SPN # 02448595, § § Plaintiff, § § VS. § CIVIL ACTION NO. 4:24-1839 § HARRIS COUNTY SHERIFF’S OFFICER § REYES, § § Defendant.

MEMORANDUM OPINION AND ORDER

The plaintiff, Scott Smith, is an inmate in the Harris County Jail. Smith proceeds pro se and in forma pauperis in this civil rights suit. Because this case is governed by the Prison Litigation Reform Act (PLRA), the Court is required to screen the pleadings and dismiss the complaint in whole or in part if it is frivolous, malicious, or fails to state a claim upon which relief may be granted. 28 U.S.C. § 1915(e)(2)(B); 28 U.S.C. § 1915A(b). Having reviewed the pleadings, the applicable law, and all matters of record, the Court concludes that this civil action should be conditionally dismissed for the reasons that follow. I. BACKGROUND

Smith names “Officer Reyes,” an officer with the Harris County Sheriff’s Office, as the sole defendant in this case. He states that on April 5, 2024, Officer Reyes was on security duty at Ben Taub Hospital. He alleges that Reyes “told 5 black people [Smith] hate[s] black people” and then “put [Smith] in a holding cell with them” and left the hospital. He also states that Reyes “admitted to his employer” that he had taken this action, which “[e]ndangered [Smith’s] life” (Dkt. 1, at 3-4). He does not allege any physical injury. As relief for his claims, he requests that the Court “compensate [him] for stress”

caused when his life was in danger (id. at 4). II. LEGAL STANDARDS Because the plaintiff is a prisoner proceeding in forma pauperis, the Court is required by the PLRA to screen the case and dismiss the complaint at any time if it determines that the complaint is frivolous, malicious, fails to state a claim upon which relief

may be granted, or seeks monetary relief against a defendant who is immune from such relief. 28 U.S.C. § 1915A(b); 28 U.S.C. § 1915(e)(2)(B). A district court may dismiss a claim as frivolous if it lacks any arguable basis in law or fact. Samford v. Dretke, 562 F.3d 674, 678 (5th Cir. 2009). A claim lacks an arguable basis in law “if it is based on an indisputably meritless legal theory.” Rogers v. Boatright, 709 F.3d 403, 407 (5th Cir.

2013) (cleaned up). It lacks an arguable basis in fact “if, after providing the plaintiff the opportunity to present additional facts when necessary, the facts alleged are clearly baseless.” Id. (cleaned up). A dismissal under § 1915A(b) or § 1915(e)(2)(B) for failure to state a claim is governed by the same standard as a motion under Rule 12(b)(6) of the Federal Rules of

Civil Procedure. See Newsome v. EEOC, 301 F.3d 227, 231 (5th Cir. 2002). Under this standard, a court “construes the complaint liberally in favor of the plaintiff,” “takes all facts pleaded in the complaint as true,” and considers whether “with every doubt resolved on [the plaintiff’s] behalf, the complaint states any valid claim for relief.” Harrington v. State Farm Fire & Cas. Co., 563 F.3d 141, 147 (5th Cir. 2009) (cleaned up). A court may dismiss a case sua sponte and without notice to the plaintiff if the plaintiff has pleaded his best case or if the dismissal is without prejudice. Brown v. Taylor, 829 F.3d 365, 370 (5th

Cir. 2016); see Bazrowx v. Scott, 136 F.3d 1053, 1054 (5th Cir. 1998) (holding that a court may sua sponte dismiss for failure to state a claim “as long as the procedure employed is fair”) (cleaned up); Jacquez v. Procunier, 801 F.2d 789, 793 (5th Cir. 1986) (holding that where the pleadings, viewed under the individual circumstances of the case, “demonstrate that the plaintiff has pleaded his best case,” dismissal on the pleadings is appropriate if the

pleadings do not adequately state a cause of action). In reviewing the pleadings, the Court is mindful of the fact that the plaintiff proceeds pro se. Complaints filed by pro se litigants are entitled to a liberal construction and, “however inartfully pleaded, must be held to less stringent standards than formal pleadings drafted by lawyers.” Erickson v. Pardus, 551 U.S. 89, 94 (2007) (cleaned

up). Even under this lenient standard a pro se plaintiff must allege more than “‘labels and conclusions’ or a ‘formulaic recitation of the elements of a cause of action.’” Ashcroft v. Iqbal, 556 U.S. 662, 678 (2009) (quoting Bell Atlantic Corp. v. Twombly, 550 U.S. 544, 555 (2007)); see Patrick v. Wal-Mart, Inc., 681 F.3d 614, 617 (5th Cir. 2012). “Threadbare recitals of the elements of a cause of action, supported by mere conclusory statements, do

not suffice.” Iqbal, 556 U.S. at 678. Additionally, regardless of how well-pleaded the factual allegations may be, they must demonstrate that the plaintiff is entitled to relief under a valid legal theory. See Neitzke v. Williams, 490 U.S. 319, 327 (1989); Geiger v. Jowers, 404 F.3d 371, 373 (5th Cir. 2005). III. ANALYSIS Smith’s civil rights claim is cognizable under 42 U.S.C. § 1983, which provides a vehicle for a claim against a person acting under color of state law, such as a law enforcement official, for a constitutional violation. Pratt v. Harris Cty., Tex., 822 F.3d 174, 180 (5th Cir. 2016). To the extent Smith raises a claim that Officer Reyes failed to

protect him, his claim arises under the Fourteenth Amendment. See Hare v. City of Corinth, 74 F.3d 633, 638-39 (5th Cir. 1996) (en banc). Smith’s claim must be dismissed because federal statute prohibits the compensatory damages he seeks. Under 42 U.S.C. § 1997e(e), “No Federal civil action may be brought by a prisoner confined in a jail, prison, or other correctional facility, for mental or emotional

injury suffered while in custody without a prior showing of physical injury or the commission of a sexual act (as defined in section 2246 of Title 18).” See Mayfield v.

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Related

Hare v. City of Corinth, Miss.
74 F.3d 633 (Fifth Circuit, 1996)
Bazrowx v. Scott
136 F.3d 1053 (Fifth Circuit, 1998)
Newsome v. EEOC
301 F.3d 227 (Fifth Circuit, 2002)
Geiger v. Jowers
404 F.3d 371 (Fifth Circuit, 2005)
Mayfield v. Texas Department of Criminal Justice
529 F.3d 599 (Fifth Circuit, 2008)
Samford v. Dretke
562 F.3d 674 (Fifth Circuit, 2009)
Harrington v. State Farm Fire & Casualty Co.
563 F.3d 141 (Fifth Circuit, 2009)
Neitzke v. Williams
490 U.S. 319 (Supreme Court, 1989)
Erickson v. Pardus
551 U.S. 89 (Supreme Court, 2007)
Bell Atlantic Corp. v. Twombly
550 U.S. 544 (Supreme Court, 2007)
Ashcroft v. Iqbal
556 U.S. 662 (Supreme Court, 2009)
Fernando Jacquez v. R.K. Procunier
801 F.2d 789 (Fifth Circuit, 1986)
Teresa Patrick v. Wal-Mart, Incorporated
681 F.3d 614 (Fifth Circuit, 2012)
Bruce Rogers v. Shawna Boatright
709 F.3d 403 (Fifth Circuit, 2013)
Farmer v. Brennan
511 U.S. 825 (Supreme Court, 1994)
Pratt Ex Rel. Estate of Pratt v. Harris County
822 F.3d 174 (Fifth Circuit, 2016)
Clarence Brown v. Allison Taylor
829 F.3d 365 (Fifth Circuit, 2016)

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Smith v. Harris County Sheriff's Officer Reyes, Counsel Stack Legal Research, https://law.counselstack.com/opinion/smith-v-harris-county-sheriffs-officer-reyes-txsd-2024.