Vann v. Meier

CourtDistrict Court, W.D. Tennessee
DecidedFebruary 20, 2024
Docket1:22-cv-01246
StatusUnknown

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

Bluebook
Vann v. Meier, (W.D. Tenn. 2024).

Opinion

UNITED STATES DISTRICT COURT WESTERN DISTRICT OF TENNESSEE EASTERN DIVISION

KENNETH RAY VANN, ) ) Plaintiff, ) ) vs. ) No. 1:22-cv-01246-SHM-tmp ) SHERIFF MEIER, ET AL., ) ) Defendants. ) )

ORDER MODIFYING THE DOCKET; DISMISSING THE COMPLAINT (ECF NO. 1) WITHOUT PREJUDICE; AND GRANTING LEAVE TO AMEND

On November 4, 2022, Plaintiff Kenneth Ray Vann filed (1) a pro se complaint pursuant to 42 U.S.C. § 1983 (ECF No. 1) and (2) a motion for leave to proceed in forma pauperis (ECF No. 2). When Vann filed the complaint, he was confined at the Madison County Jail (the “MCJ”), in Jackson, Tennessee. (ECF No. 1 at PageID 2.) On November 23, 2022, the Court granted leave to proceed in forma pauperis and assessed the three hundred and fifty dollar ($350.00) civil filing fee pursuant to the Prison Litigation Reform Act, 28 U.S.C. §§ 1915, et seq. (the “PLRA”). (ECF No. 6 (the “IFP Order”).) The complaint (ECF No. 1) is before the Court. Vann alleges that, while he was confined at the MCJ “from 6/21 to 9/22 and from 9/22 till now”, he experienced overcrowded conditions of confinement, slept on the floor “for 18 plus[] months”, and was exposed to “a plague of black mold.” (Id. at PageID 2.) It is unclear from the complaint whether Vann experienced the alleged conditions from June through September of 2021 or 2022. (See id.) Vann does not identify the dates of the events and conditions alleged in the complaint. (See id.) Vann sues two (2) defendants: (1) Sheriff Meier1; and (2) Sheriff J. Wiser. (Id.) Vann seeks “some kind” of unspecified relief. (Id. at PageID 3.) The Clerk is DIRECTED to: (1) modify the docket to add Madison County, Tennessee (the “County”) as a Defendant; and (2) modify the docket to change the name of Defendant Sheriff Meier to Defendant Sheriff Mehr. For the reasons explained below: (1) the complaint (ECF No. 1) is DISMISSED WITHOUT PREJUDICE; and (2) leave to amend is GRANTED.

I. LEGAL STANDARD The Court must screen prisoner complaints and dismiss any complaint, or any portion of it, if the complaint — (1) is frivolous, malicious, or fails to state a claim upon which relief may be granted; or (2) seeks monetary relief from a defendant who is immune from such relief.

28 U.S.C. § 1915A(b); see also 28 U.S.C. § 1915(e)(2)(B). In assessing whether the complaint states a claim on which relief may be granted, the Court applies the standards under Federal Rule of Civil Procedure 12(b)(6), as stated in Ashcroft v. Iqbal, 556 U.S. 662, 677–79 (2009), and in Bell Atlantic Corp. v. Twombly, 550 U.S. 544, 555–57 (2007). Hill v. Lappin, 630 F.3d 468, 470–71 (6th Cir. 2010). Under those standards, the Court accepts the complaint’s “well-pleaded” factual allegations as true and then determines whether the allegations “plausibly suggest an entitlement to relief.” Williams v. Curtin, 631 F.3d 380, 383 (6th Cir. 2011) (quoting Iqbal, 556 U.S. at 681). The Court does not assume that conclusory allegations are true, because they are not “factual,” and all legal conclusions in a complaint “must be supported by factual allegations.” Iqbal, 556 U.S. at 679. Federal Rule of Civil Procedure 8 provides

1 Defendant “Meier” is understood to be the former Sheriff of Madison County, John Mehr. The Clerk is DIRECTED to modify the docket to reflect that the defendant is John Mehr, and the Court will refer to defendant as Mehr going forward. guidance on this issue. Although Rule 8 requires a complaint to contain “a short and plain statement of the claim showing that the pleader is entitled to relief,” it also requires factual allegations to make a “‘showing,’ rather than a blanket assertion, of entitlement to relief.” Twombly, 550 U.S. at 555 n.3. Courts screening cases accord more deference to pro se complaints than to those drafted by lawyers. “Pro se complaints are to be held ‘to less stringent standards than formal pleadings drafted by lawyers,’ and should therefore be liberally construed.” Williams, 631 F.3d at 383

(quoting Martin v. Overton, 391 F.3d 710, 712 (6th Cir. 2004)). Pro se litigants are not exempt from the requirements of the Federal Rules of Civil Procedure. Wells v. Brown, 891 F.2d 591, 594 (6th Cir. 1989); see also Brown v. Matauszak, 415 F. App’x 608, 612, 613 (6th Cir. 2011) (affirming dismissal of pro se complaint for failure to comply with “unique pleading requirements” and stating “a court cannot ‘create a claim which [a plaintiff] has not spelled out in his pleading’” (quoting Clark v. Nat’l Travelers Life Ins. Co., 518 F.2d 1167, 1169 (6th Cir. 1975))). II. ANALYSIS Vann does not allege whether he sues Mehr and Wiser in their official or individual capacities. (See ECF No. 1.) The Sixth Circuit requires plaintiffs to “set forth clearly in their pleading that they are suing the state defendants in their individual capacity for damages, not

simply in their capacity as state officials.” Wells, 891 F.2d at 592. “Absent a specification of capacity, it is presumed that a state official is sued in his official capacity.” Northcott v. Plunkett, 42 F. App'x 795, 796 (6th Cir. 2002) (citing Wells, 891 F.2d at 593). The Court construes Vann’s claims against Mehr and Wiser as official capacity claims. Vann’s official capacity claims against Mehr and Wiser are treated as claims against their employer at the time relevant to the complaint — i.e., the County. See Jones v. Union Cnty., Tennessee, 296 F.3d 417, 421 (6th Cir. 2002) (citing Matthews v. Jones, 35 F.3d 1046, 1049 (6th Cir. 1994)). The County may be held liable only if Vann’s injuries were sustained pursuant to an unconstitutional custom or policy of the County. See Monell v. Dep’t. of Soc. Serv., 436 U.S. 658, 691-92 (1978). To demonstrate municipal liability, a plaintiff “must (1) identify the municipal policy or custom, (2) connect the policy to the municipality, and (3) show that his particular injury was incurred due to execution of that policy.” Alkire v. Irving, 330 F.3d 802, 815 (6th Cir.

2003) (citing Garner v. Memphis Police Dep't, 8 F.3d 358, 364 (6th Cir. 1993)).

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Vann v. Meier, Counsel Stack Legal Research, https://law.counselstack.com/opinion/vann-v-meier-tnwd-2024.