Smith v. Hogan

CourtDistrict Court, S.D. Ohio
DecidedOctober 2, 2024
Docket2:24-cv-02620
StatusUnknown

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

Bluebook
Smith v. Hogan, (S.D. Ohio 2024).

Opinion

UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF OHIO EASTERN DIVISION AT COLUMBUS

GERALD K. SMITH, : Case No. 2:24-cv-02620 : Plaintiff, : : District Judge Michael H. Watson vs. : Magistrate Judge Caroline H. Gentry : D. HOGAN, et. al., : : Defendants. :

REPORT AND RECOMMENDATION AND ORDER

Gerald K. Smith recently filed a Complaint under 42 U.S.C. § 1983 with this Court. (Doc. No. 1-1.) He asserts that his rights were violated by a prison order prohibiting inmates from using the toilet during certain time periods. (Id.) Plaintiff Smith is proceeding in the case in forma pauperis and without the assistance of counsel. The matter is currently before the undersigned United States Magistrate Judge to screen the Complaint and determine whether it, or any portion of it, should be dismissed because it is frivolous, 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 28 U.S.C. § 1915(e)(2) (screening required where plaintiff proceeds in forma pauperis); 28 U.S.C. § 1915A (screening required where “a prisoner seeks redress from a governmental entity or officer or employee of a governmental entity”). In the Complaint, Plaintiff alleges that D. Hogan, Chief of Security at London Correctional Institution (“LoCI”), posted an order “deny[ing] all inmates access to toilets

‘after dorm count had already been cleared by the count office.’” (Doc. No. 1-1 at PageID 14, 16.) Plaintiff was allegedly denied access to toilets and washbasins on 40 or more occasions from 2018 to 2022, which caused him so much pain that he soiled himself. (Id. at PageID 17.) Plaintiff further alleges that LoCI Warden Norman Robinson, Deputy Warden Stanley Taylor, Unit Manager J. Condrac, and Inspector DeCarlo Blackwell all knew or should have known that Hogan’s order violated the law and prison policy but did

not act to abolish it. (Id. at PageID 16.) For relief, Plaintiff seeks monetary damages from each of these Defendants. (Id. at PageID 17.) At this early stage in the proceedings, without the benefit of an answer or other briefing, the undersigned concludes that Plaintiff’s primary claim—his Eighth Amendment claim against Defendant Hogan in his individual capacity—may

PROCEED to further development. The undersigned expresses no opinion on the merits of this claim or whether there may be defenses or procedural bars that will prevent him from ultimately obtaining relief. To move this part of the case forward, Plaintiff is ORDERED to complete and submit a new summons form and U.S. Marshal form for Defendant Hogan only within

thirty days. He must include his own address as plaintiff in the space provided on the summons form. (Cf. Doc. Nos. 1-3 and 1-4 (listing all named defendants together on one form and omitting Plaintiff’s address from the summons form).) The Court will provide these forms. Once Plaintiff completes and returns these forms to the Court, the United States Marshal Service is DIRECTED to serve a copy of the Summons, the Complaint, and this Order on Defendant Hogan. The costs of service shall be advanced by the United

States. If Plaintiff fails to provide the completed forms within thirty (30) days from the date this decision is filed, his case may be dismissed for failure to prosecute. The undersigned recommends only that Plaintiff’s claim against Defendant Hogan in his individual capacity be permitted to proceed to further development. Plaintiff’s remaining claims, i.e., those asserted against all Defendants in their official capacities, and those against the other four Defendants as supervisors, should be DISMISSED.

Official Capacity Claims for Damages Claims for monetary damages against state employees or officials in their official capacities are barred by the Eleventh Amendment to the United States Constitution. Maben v. Thelen, 887 F.3d 252, 270 (6th Cir. 2018). The Eleventh Amendment “denies to the federal courts authority to entertain a suit brought by private parties against a state

without its consent.” Id. at 270 (quoting Ford Motor Co. v. Dep’t of Treasury of Indiana, 323 U.S. 459, 464 (1945)). The state’s immunity also “extends to state officials sued in their official capacity” for monetary damages. Smith v. DeWine, 476 F. Supp. 3d 635, 650-51 (S.D. Ohio 2020). This is “because ‘a suit against a state official in his or her official capacity is not a suit against the official but rather is a suit against the official’s

office. . . . As such, it is no different from a suit against the State itself.’” Zakora v. Chrisman, 44 F. 4th 452, 474 (6th Cir. 2022) (quoting Will v. Mich. Dep’t of State Police, 491 U.S. 58, 63-64, 71 (1989) (citations omitted)). See also Monell v. Dep’t of Soc. Services, 436 U.S. 658, 690 n.55 (1978) (holding that “neither a State nor its officials acting in their official capacities are ‘persons’” who may be held liable for constitutional violations in a § 1983 action).

Here, Plaintiff alleges that Defendants are state officials or employees affiliated with LoCI, a correctional institution run by the Ohio Department of Rehabilitation and Correction (“ODRC”). (Doc. No. 1-1 at PageID 14-15.) All claims for monetary damages (see id. at PageID 17) against them in their official capacities are barred by the Eleventh Amendment and should be dismissed. See 28 U.S.C. §§ 1915(e)(2)(B) and 1915A(b)(2) (requiring dismissal of a complaint that seeks monetary relief against a defendant who is

immune from that relief). Supervisory Liability Plaintiff’s allegations against Defendants Robinson, Taylor, Condrac and Blackwell (collectively the “Supervisor Defendants”) fail to state a claim on which relief may be granted. Plaintiff alleges that the Supervisor Defendants “are members of the

administration department . . . in a position superior to defendant D. Hogan, who is a member of prison security.” (Doc. No. 1-1 at PageID 16.) Plaintiff alleges that these Defendants “took no action whatsoever” with respect to Hogan’s order, even though they “knew or should have known [that the] order was in direct violation of clearly established policies and [the] U.S. Constitution.” (Id.) Plaintiff asserts that although these Defendants

were not “the primary actor,” they knew that Hogan’s order violated ODRC’s policies and the law. (Id. at PageID 17.) Plaintiff also asserts that when these Defendants failed to object to Hogan’s order, “they became personally involved” in the violation. (Id.) Given Plaintiff’s allegation that the Supervisor Defendants were in a superior position over Defendant Hogan, he appears to sue them based on supervisory liability.

(Doc. No. 1-1 at PageID 16-17.) On its own, this alleged fact is insufficient to hold them liable. Peatross v. City of Memphis, 818 F.3d 233, 241 (6th Cir. 2016) (citing Gregory v.

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Scott Peatross v. City of Memphis
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James Maben v. Troy Thelen
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Smith v. Hogan, Counsel Stack Legal Research, https://law.counselstack.com/opinion/smith-v-hogan-ohsd-2024.