Vanderbilt v. Arkansas Department of Corrections

CourtDistrict Court, E.D. Arkansas
DecidedJanuary 20, 2023
Docket4:22-cv-01108
StatusUnknown

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

Bluebook
Vanderbilt v. Arkansas Department of Corrections, (E.D. Ark. 2023).

Opinion

IN THE UNITED STATES DISTRICT COURT EASTERN DISTRICT OF ARKANSAS CENTRAL DIVISION

GARLAND VANDERBILT, PLAINTIFF ADC # 137333

v. 4:22CV01108-BRW-JTK

ARKANSAS DEPARTMENT OF CORRECTIONS DEFENDANT

ORDER Garland Vanderbilt (“Plaintiff”), in custody at the Pine Bluff Unit of the Arkansas Division of Correction, filed a Complaint alleging violations of his constitutional rights. (Doc. No. 1). Plaintiff paid the $402 filing fee for this action. (Doc. No. 5). The Prison Litigation Reform Act (“PLRA”) requires federal courts to screen prisoner complaints seeking relief against a governmental entity, officer, or employee, regardless of fee status. 28 U.S.C. ' 1915A(a); Lewis v. Estes, 242 F.3d 375 (8th Cir. 2000) (per curiam) (§ 1915A’s screening requirement applies regardless of fee status). After reviewing Plaintiff’s claims, the Court finds that Plaintiff’s Complaint as currently pled fails to state a claim on which relief may be granted. Plaintiff will be given the chance to file an Amended Complaint if he wishes to do so. I. Screening The PLRA requires federal courts to screen prisoner complaints seeking relief against a governmental entity, officer, or employee. 28 U.S.C. ' 1915A(a). The Court must dismiss a complaint or portion thereof if the prisoner has raised claims that: (a) are legally frivolous or malicious; (b) fail to state a claim upon which relief may be granted; or (c) seek monetary relief from a defendant who is immune from such relief. 28 U.S.C. ' 1915A(b). An action is frivolous if “it lacks an arguable basis either in law or in fact.” Neitzke v. Williams, 490 U.S. 319, 325 (1989). Whether a plaintiff is represented by counsel or is appearing pro se, his complaint must allege specific facts sufficient to state a claim. See Martin v. Sargent,

780 F .2d 1334, 1337 (8th Cir.1985). An action fails to state a claim upon which relief can be granted if it does not plead “enough facts to state a claim to relief that is plausible on its face.” Bell Atlantic Corp. v. Twombly, 550 U.S. 544, 570 (2007). In reviewing a pro se complaint under ' 1915(e)(2)(B), the Court must give the complaint the benefit of a liberal construction. Haines v. Kerner, 404 U.S. 519, 520 (1972). The Court must also weigh all factual allegations in favor of the plaintiff, unless the facts alleged are clearly baseless. Denton v. Hernandez, 504 U.S. 25, 32 (1992). II. Plaintiff’s Complaint Plaintiff “ma[d]e [his] petition of complaint . . . against the Arkansas Department of Corrections.” (Doc. No. 1 at 1). Plaintiff says that a Corporal Tate acted unprofessionally.

(Id. at 2). Specifically, Plaintiff alleges Corporal Tate retaliated against Plaintiff for Plaintiff writing a statement against Corporal Tate regarding an incident in 9C in which Corporal Tate abused an inmate. (Id. at 2, 5). Plaintiff asserts that Corporal Tate seeks revenge against all inmates who wrote witness statements against him. (Id. at 2-3). Plaintiff alleges “neither Administrative Director” investigated claims that Plaintiff set out in grievances. (Id. at 1). Liberally construing Plaintiff’s Complaint, he also alleges failure to supervise. (Id. at 2-3). Plaintiff seeks “reprieve . . . from the oppressive supervision of” Corporal Tate. (Doc. No. 1 at 3). III. Discussion For the reasons set out below, Plaintiff’s Complaint as currently pled fails to state a claim on which relief may be granted. Plaintiff will be given the chance to submit an Amended Complaint to cure the deficiencies, if he wishes to do so.

A. Arkansas Department of Corrections Plaintiff brought his complaints against the Arkansas Department of Corrections. Plaintiff’s claims fall under 42 U.S.C. § 1983. Plaintiff’s Complaint fails because the Arkansas Department of Corrections is not a “person” subject to suit under 42 U.S.C. § 1983. Zar v. S.D. Bd. of Exam’rs of Psychologists, 976 F.2d 459, 464 (8th Cir. 1992) (state departments not “persons” under § 1983). B. Plaintiff May Not Represent the Claims of Others “[F]or a federal court to have authority under the Constitution to settle a dispute, the party before it must seek a remedy for a personal and tangible harm.” Hollingsworth v. Perry, 570 U.S. 693, 704 (2013). See also 42 U.S.C. § 1983 (establishing liability “to the party injured). To the extent a plaintiff alleges that a defendant’s actions harmed others, the plaintiff generally lacks standing to bring that claim. Hodak v. City of St. Peters, 535 F.3d 899, 904 (8th Cir. 2008) (“As

a general rule, a plaintiff may only assert his own injury in fact and ‘cannot rest his claim to relief on the legal rights or interests of third parties.’” (internal citation omitted)). Further, pro se litigants are not authorized to represent the rights, claims and interests of other parties in any cause of action, including a class action lawsuit. Fymbo v. State Farm Fire and Cas. Co., 213 F.3d 1320, 1321 (10th Cir. 2000) (“A litigant may bring his own claims to federal court without counsel, but not the claims of others”); Oxendine v. Williams, 509 F.2d 1405, 1407 (4th Cir. 1975); cf. Knoefler v. United Bank of Bismarck, 20 F.3d 347, 348 (8th Cir. 1994) (“A nonlawyer . . . has no right to represent another entity.”). In Plaintiff’s Complaint, he refers to Corporal Tate’s abusive behavior towards other inmates and prison staff. To the extent Plaintiff seeks to bring claims on behalf of others, he may

not do so. C. Personal Capacity Claims “Liability under § 1983 requires a causal link to, and direct responsibility for, the alleged deprivation of rights.” Madewell v. Roberts, 909 F.2d 1203, 1208 (8th Cir. 1990). “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.” Parrish v. Ball, 594 F.3d 993, 1001 (8th Cir. 2010) (citing Ashcroft v. Iqbal, 556 U.S. 662, 676 (2009)). Bare allegations void of factual enhancement are insufficient to state a claim for relief under § 1983. See Iqbal, 556 U.S. at 678. 1. Failure to Investigate Grievances Because the “[prison] grievance procedure is a procedural right only, it does not confer any substantive right upon the inmates.... it does not give rise to a protected liberty interest requiring the procedural protections envisioned by the fourteenth amendment.” Buckley v. Barlow, 997

F.2d 494, 495 (8th Cir. 1993) (quoting Azeez v. DeRobertis, 568 F.Supp. 8, 10 (N.D. Ill. 1982)). Plaintiff “does not have a federal claim regarding how his grievances were processed, investigated, or responded to, even if they were not done by the appropriate personnel or in accord with the policies.” Edgar v. Crawford, No. 08-4279-CV-C-SOW, 2009 WL 3835265, *3 (W.D. Mo. 2009).

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Related

Haines v. Kerner
404 U.S. 519 (Supreme Court, 1972)
Neitzke v. Williams
490 U.S. 319 (Supreme Court, 1989)
Denton v. Hernandez
504 U.S. 25 (Supreme Court, 1992)
Bell Atlantic Corp. v. Twombly
550 U.S. 544 (Supreme Court, 2007)
Ashcroft v. Iqbal
556 U.S. 662 (Supreme Court, 2009)
Fymbo v. State Farm Fire & Casualty Co.
213 F.3d 1320 (Tenth Circuit, 2000)
Donald Earl Atkinson v. Susan Bohn Phil Jefferson
91 F.3d 1127 (Eighth Circuit, 1996)
Gatlin v. Green
362 F.3d 1089 (Eighth Circuit, 2004)
Victor Santiago v. Daniel Blair
707 F.3d 984 (Eighth Circuit, 2013)
Hollingsworth v. Perry
133 S. Ct. 2652 (Supreme Court, 2013)
Hodak v. City of St. Peters
535 F.3d 899 (Eighth Circuit, 2008)
Parrish v. Ball
594 F.3d 993 (Eighth Circuit, 2010)
Azeez v. DeRobertis
568 F. Supp. 8 (N.D. Illinois, 1982)
Rienholtz v. Campbell
64 F. Supp. 2d 721 (W.D. Tennessee, 1999)
Mark Bitzan v. Jerry Bartruff
916 F.3d 716 (Eighth Circuit, 2019)
Choate v. Lockhart
7 F.3d 1370 (Eighth Circuit, 1993)

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Vanderbilt v. Arkansas Department of Corrections, Counsel Stack Legal Research, https://law.counselstack.com/opinion/vanderbilt-v-arkansas-department-of-corrections-ared-2023.