Vinyard v. Madison County Jail

CourtDistrict Court, W.D. Tennessee
DecidedApril 22, 2025
Docket1:22-cv-01143
StatusUnknown

This text of Vinyard v. Madison County Jail (Vinyard v. Madison County Jail) 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
Vinyard v. Madison County Jail, (W.D. Tenn. 2025).

Opinion

UNITED STATES DISTRICT COURT WESTERN DISTRICT OF TENNESSEE WESTERN DIVISION

JEFFREY B. VINYARD, ) ) Plaintiff, ) ) vs. ) No. 1:22-cv-1143-SHM-tmp ) MADISON COUNTY JAIL, ET AL., ) ) Defendants. )

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

On July 5, 2022, Plaintiff Jeffrey B. Vinyard filed a pro se complaint under 42 U.S.C. § 1983 (ECF No. 1) and a motion for leave to proceed in forma pauperis (ECF No. 2). When Vinyard filed the complaint, he was confined at the Madison County Jail (the “MCJ”), in Jackson, Tennessee. (ECF No. 1 at PageID 2.) On July 15, 2022, the Court granted leave to proceed in forma pauperis. (ECF No. 5.) In his complaint, Vinyard alleges: (1) denial of his due process rights under the Fourteenth Amendment because the MCJ did not book Vinyard “into the[i]r agency on April 27, 2022”; (2) “police misconduct” and “unprofessional ethics” by the Jackson Police Department (the “JPD”) on April 27, 2022; and (3) “unprofessional ethics, excessive force, and harassment” by Officer Boxley1 of the JPD on April 27, 2022. (ECF No. 1 at PageID 2.) Vinyard alleges no facts about the circumstances of the April 27, 2022 conduct. (See id.) Vinyard sues four Defendants: (1) the

1 Vinyard’s spelling in the complaint of Officer Boxley’s name is inconsistent. (See ECF No. 1 at PageID 1 (“Boxely”); id. at PageID 2 (“Boxely” and “Boxley”).) MCJ; (2) the JPD; (3) Officer F/N/U Boxley; and (4) the Madison County Sheriff’s Department (the “MCSD”). (Id. at PageID 1-2.) Vinyard seeks: (1) “compensation”; (2) “justice”; and (3) “my freedom reinstated.” (Id. at PageID 3.) The Clerk shall MODIFY the docket to add these Defendants: (1) Madison County,

Tennessee (the “County”); and (2) the City of Jackson, Tennessee (the “City”). The complaint (ECF No. 1) is before the Court. For the reasons explained below: (1) the complaint (ECF No. 10) is DISMISSED WITHOUT PREJUDICE in its entirety for failure to state a claim to relief; 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 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. REQUIREMENTS TO STATE A CLAIM UNDER § 1983 Vinyard sues under 42 U.S.C. § 1983. (ECF No. 1 at PageID 1.) To state a claim under § 1983, a plaintiff must allege two elements: (1) a deprivation of rights secured by the “Constitution and laws” of the United States, and (2) that a defendant caused harm while acting under color of state law. Adickes v. S.H. Kress & Co., 398 U.S. 144, 150 (1970). III. ANALYSIS A. Claims Against The MCJ, The JPD, The MCSD, The County, And The City To the extent Vinyard alleges a claim against the MCJ, Vinyard fails to state a claim to relief as a matter of law. Under § 1983, a jail is not a “person” subject to suit. See Marbry v. Corr. Med. Serv., 238 F.3d 422 (table), No. 99-6706, 2000 WL 1720959, at *2 (6th Cir. Nov. 6, 2000) (citing Rhodes v. McDannel, 945 F.2d 117, 120 (6th Cir. 1991)). To the extent Vinyard alleges a claim against the JPD and the MCSD, Vinyard fails to state a claim to relief as a matter of law. It is well-established in the Sixth Circuit that

a police department, such as the MCSD, is not a proper defendant in a § 1983 action. See Matthews v. Jones, 35 F.3d 1046, 1049 (6th Cir. 1994) (“[T]he Police Department is not an entity which may be sued”). “[S]ince Matthews, federal district courts in Tennessee have frequently and uniformly held that police departments and sheriff’s departments are not proper parties to a § 1983 suit.” Mathes v. Metro Gov’t of Nashville & Davidson Cnty., 2010 WL 3341889, at *2 (M.D. Tenn., Aug. 25, 2010). The Court construes Vinyard’s claims against the MCJ and the MCSD as claims against the County. See Marbry, 238 F.3d 422 (table), 2000 WL 1720959, at *2. The Court construes Vinyard’s claim against the JPD as a claim against the City. Id.; see also Sargent v. City of Toledo Police Dep’t, 150 Fed. App’x 470, 475 (6th Cir. 2005) (police departments can properly be

characterized as “sub-units of the municipalities they serve”); accord Kindle v. City of Jeffersontown, Ky., 374 F. App’x 562, 570 (6th Cir. 2010); Duck v. Madison Cnty. Sheriff’s Dep’t, No. 17-1043, 2018 WL 2966950, at *3 (W.D. Tenn.

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Vinyard v. Madison County Jail, Counsel Stack Legal Research, https://law.counselstack.com/opinion/vinyard-v-madison-county-jail-tnwd-2025.