Sol-Damacus Burke v. Warden David Zook, et al.

CourtDistrict Court, W.D. Virginia
DecidedMay 15, 2026
Docket7:25-cv-00480
StatusUnknown

This text of Sol-Damacus Burke v. Warden David Zook, et al. (Sol-Damacus Burke v. Warden David Zook, et al.) is published on Counsel Stack Legal Research, covering District Court, W.D. Virginia primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Sol-Damacus Burke v. Warden David Zook, et al., (W.D. Va. 2026).

Opinion

CLERKS OFFICE US DISTRICT CC AT ROANOKE, VA FILED IN THE UNITED STATES DISTRICT COURT May 15, 2026 FOR THE WESTERN DISTRICT OF VIRGINIA LAURA A. AUSTIN, CLERK ROANOKE DIVISION By: /s/ M. Poff DEPUTY CLERK SOL-DAMACUS BURKE, ) Plaintiff, ) ) V. ) Civil Action No. 7:25-cv-00480 ) WARDEN DAVID ZOOK, et al., ) By: Robert S. Ballou Defendants. ) United States District Judge MEMORANDUM OPINION Plaintiff Sol-Damacus Burke, a Virginia inmate proceeding pro se, has filed a civil rights action pursuant to 42 U.S.C. § 1983. Dkt. 1, 4. Having reviewed this action pursuant to 28 U.S.C. § 1915A, I will dismiss the Amended Complaint for failure to state a claim upon which relief may be granted. “Section 1983 imposes liability on state actors who cause the ‘deprivation of any rights, privileges, or immunities secured by the Constitution.’” Doe v. Rosa, 795 F.3d 429, 436 (4th Cir. 2015). However, the court must dismiss any action filed by a prisoner against a state defendant if the claims are frivolous, malicious, or fail to state a claim upon which relief may be granted. 28 U.S.C. § 1915A(b)(1). The plaintiff's “[flactual allegations must be enough to raise a right to relief above the speculative level,” to one that is “plausible on its face,” rather than merely “conceivable.” Bell Atl. Corp v. Twombly, 550 U.S. 544, 555, 570 (2007).

' Burke initially filed a pleading he designated as a petition for writ of habeas corpus under 28 U.S.C. § 2254. Dkt. 1. However, as Burke was challenging the constitutionality of prison conditions instead of the validity of his conviction or length of his sentence, the court construed it as an action under § 1983 and instructed Burke to file an Amended Complaint, which he did. Dkt. 3, 4.

Burke alleges excessive force and inhumane prison conditions in violation of the Eighth Amendment against staff at both Wallens Ridge State Prison and Red Onion State Prison, but he fails to identify the staff members at fault in his Amended Complaint. Dkt. 4. The single staff member identified, Officer Robertson, is named in an exhibit signed by another inmate and alleges excessive force against that inmate, not Burke. Dkt. 4-1. Burke names as defendants

Warden Zook, Chief of Security Hall, Operations Manager Rose, Hearing Officer King, Regional Ombudsman Meade, along with several circuit court judges2 and a clerk of the circuit court but includes no factual allegations against these defendants. Dkt. 4. Burke alleges that on May 15, 2024, he and several other inmates were escorted to B-4, a restricted housing unit at Red Onion, despite Burke being assigned to A-1 housing unit. Id. Officers “cuffed and shackled” Burke to a table for more than four hours, but completed none of the required procedural steps necessary to move an inmate to restricted housing. Id. Burke alleges that unidentified “D.O.C. staff” assaulted him while he was in “full restraints, not posing any threat to staff or inmates.” Id. After submitting an informal complaint about this incident at Red Onion, Burke “as reprisal” was

transferred to Wallens Ridge. Id. Since his transfer, Burke complains that has been “falsely written up, had personal property destroyed by staff, [and been] subjected to inhuman[e] treatment” including confinement in a restricted housing unit, and being “locked in cell for 24 hours a day for months with no outside recreation” and no access to the law library. Id.

2 Burke references an “independent action” currently before the Supreme Court of Virginia and requests “joinder” of that case and those defendants, pursuant to Federal Rules of Civil Procedure 18, 19, and 20. Dkt. 4. However, “joinder” of a state court lawsuit is not permitted under these Rules. Further, a plaintiff may only join different defendants in the same suit if the claims against them arose out of the same transaction or occurrence, or series thereof, and contain a question of fact or law common to all defendants. Fed. R. Civ. P. 20(a)(2). “[T]he treatment a prisoner receives in prison and the conditions under which he is confined are subject to scrutiny under the Eighth Amendment.” Farmer v. Brennan, 511 U.S. 825, 832 (1994) (citations omitted). The Eighth Amendment requires that prison officials “provide humane conditions of confinement; prison officials must ensure that inmates receive adequate food, clothing, shelter, and medical care.” Id. The Eighth Amendment also forbids “the

unnecessary and wanton infliction of pain.” Whitley v. Albers, 475 U.S. 312, 319 (1986). A prisoner bringing an Eighth Amendment excessive force claim must make both an objective and subjective showing. Alexander v. Connor, 105 F.4th 174, 182 (4th Cir. 2024). The objective prong “asks whether the force applied was sufficiently serious to establish a cause of action.” Id. (quoting Brooks v. Johnson, 924 F.3d 104, 112 (4th Cir. 2019)). “This is not a high bar, requiring only something more than ‘de minimis’ force.” Brooks, 924 F.3d at 112. On the other hand, the subjective prong, is a more “demanding standard” that asks whether the officer acted with “a sufficiently culpable state of mind.” Alexander, 105 F.4th at 182 (quoting Brooks, 924 F.3d at 112, 119).

As stated, Burke fails to identify the prison staff he alleges violated his constitutional rights, including by using excessive force or imposing inhumane prison conditions. Liability under § 1983 is “personal, based upon each defendant’s own constitutional violations.” Trulock v. Freeh, 275 F.3d 391, 402 (4th Cir. 2001) (internal citation omitted). For this reason, a § 1983 claim requires factual detail about each defendant’s personal involvement. See Wilcox v. Brown, 877 F.3d 161, 170 (4th Cir. 2017); Ashcroft v. Iqbal, 556 U.S. 662, 676-77 (“Because vicarious liability is inapplicable to . . . § 1983 suits, a plaintiff must plead that each Government-official defendant, through the official’s own individual actions, has violated the Constitution”). Simply put, Burke must name every defendant he intends to bring a § 1983 action against in the caption of the complaint and specifically describe in the body of the complaint how each defendant violated Burke’s federal rights.3 Burke also lists four other inmates as plaintiffs in this action, but Burke as a pro se plaintiff, is not permitted to represent other pro se individuals. 4 Hummer v. Dalton, 657 F.2d 621, 625–26 (4th Cir. 1981) (a prisoner’s lawsuit is “confined to redress for violation of his own

personal rights and not one by him as a knight-errant for all prisoners”); Myers v. Loudoun Cnty.

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Related

Whitley v. Albers
475 U.S. 312 (Supreme Court, 1986)
Bell Atlantic Corp. v. Twombly
550 U.S. 544 (Supreme Court, 2007)
Ashcroft v. Iqbal
556 U.S. 662 (Supreme Court, 2009)
Oxendine v. Williams
509 F.2d 1405 (Fourth Circuit, 1975)
Farmer v. Brennan
511 U.S. 825 (Supreme Court, 1994)
Doe 2 v. John Rosa
795 F.3d 429 (Fourth Circuit, 2015)
Torrey F. Wilcox v. Betty Brown
877 F.3d 161 (Fourth Circuit, 2017)
Altony Brooks v. Captain Jacumin
924 F.3d 104 (Fourth Circuit, 2019)
Trulock v. Freeh
275 F.3d 391 (Fourth Circuit, 2001)
Myers v. Loudoun County Public Schools
418 F.3d 395 (Fourth Circuit, 2005)
Hummer v. Dalton
657 F.2d 621 (Fourth Circuit, 1981)
Thomas Alexander v. Sergeant Connor
105 F.4th 174 (Fourth Circuit, 2024)

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Bluebook (online)
Sol-Damacus Burke v. Warden David Zook, et al., Counsel Stack Legal Research, https://law.counselstack.com/opinion/sol-damacus-burke-v-warden-david-zook-et-al-vawd-2026.