Wade v. Mehr

CourtDistrict Court, W.D. Tennessee
DecidedFebruary 21, 2024
Docket1:22-cv-01006
StatusUnknown

This text of Wade v. Mehr (Wade v. Mehr) 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
Wade v. Mehr, (W.D. Tenn. 2024).

Opinion

UNITED STATES DISTRICT COURT WESTERN DISTRICT OF TENNESSEE EASTERN DIVISION

MAX R. WADE, ) ) Plaintiff, ) ) vs. ) No. 1:22-cv-01006-SHM-tmp ) JOHN MEHR, ET AL., ) ) Defendants. ) )

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

On January 11, 2022, Plaintiff Max R. Wade 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 Wade filed the complaint, he was confined at the Madison County Jail (the “MCJ”), in Jackson, Tennessee. (ECF No. 1 at PageID 2.) On January 21, 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. 4 (the “IFP Order”).) The complaint (ECF No. 1) is before the Court. Wade alleges claims of: (1) unconstitutional conditions of confinement arising from double celling inmates, deprivation of hot water for more than one (1) week, “buildings unfit for human habitation”, and unsanitary food service; (2) failure to protect; (3) deprivation of medical care; and (4) deprivation of recreation. (Id. at PageID 2.) Wade does not identify the dates of the events and conditions alleged in the complaint. (See id.) Wade sues two (2) defendants as “Madison County government official[s]”: (1) Sheriff John Mehr; and (2) Mayor Scott Conger. (Id. at PageID 2.) Wade seeks: (1) one million dollars ($1,000,000.00) as compensation; and (2) injunctive relief to “stop cruel and unusual punishment”, overcrowding, and black mold. (Id. at PageID 3.) The Clerk is DIRECTED to modify the docket to: (1) remove “Madison County Government Official” as a Defendant1; (2) add Madison County, Tennessee (the “County”) as a Defendant; and (3) add the City of Jackson, Tennessee (the “City”) as a Defendant.

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

1 Wade sues (1) Madison County Sheriff John Mehr and (2) City of Jackson Mayor Scott Conger. (See ECF No. 1 at PageID 1.) The Clerk has inadvertently docketed “Madison County Government Official”, a phrase Wade uses to describe the employment positions of Mehr and Conger (see id. at PageID 1-2), as a third Defendant. 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. ANALYSIS

Wade does not allege whether he sues Mehr and Conger 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 Wade’s claims against Mehr and Conger as official capacity claims. Wade’s official capacity claims against Mehr are treated as claims against Mehr’s employer at the time the complaint was filed — 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)). Wade’s official capacity claims against Conger are treated as claims against Conger’s employer at the time the complaint was filed – i.e., the City. The County may be held liable only if Wade’s injuries were sustained pursuant to an unconstitutional custom or policy of the County. The City may be held liable only if Wade’s

injuries were sustained pursuant to an unconstitutional custom or policy of the City. See Monell v. Dep’t. of Soc. Serv., 436 U.S. 658, 691-92 (1978).

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Wade v. Mehr, Counsel Stack Legal Research, https://law.counselstack.com/opinion/wade-v-mehr-tnwd-2024.