Watson v. Benjamin

CourtDistrict Court, D. Delaware
DecidedOctober 10, 2025
Docket1:24-cv-00966
StatusUnknown

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

Bluebook
Watson v. Benjamin, (D. Del. 2025).

Opinion

IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF DELAWARE

TERRANCE WATSON, ) ) Plaintiff, ) ) v. ) C.A. No. 24-966 (JLH) ) ANDREAS BENJAMIN, et al., ) ) Defendant. )

MEMORANDUM OPINION

Terrance Watson, Howard R. Young Correctional Institution, Wilmington, Delaware – Pro Se Plaintiff

October 10, 2025 Wilmington, Delaware I. INTRODUCTION On August 21, 2024, Plaintiff Terrance Watson, who is presently incarcerated at Howard R. Young Correctional Institution (HRYCI) in Wilmington, Delaware, initiated this civil action pro se with the filing of a complaint. (DI. 2.) Plaintiffhas been granted leave to proceed in forma pauperis. (D.I. 5.) The Court proceeds to review and screen the first and second amended complaints (D.I. 9, 14), under 28 U.S.C. § 1915(e)(2)(b). Il. BACKGROUND The first and second amended complaints raise civil rights violations, under 42 U.S.C. § 1983, for which Plaintiff seeks monetary damages and injunctive relief. (D.I. 9 at 13.) The following facts are taken from Plaintiff's pleadings and assumed to be true for purposes of screening the Complaint. See Shorter v. United States, 12 F 4th 366, 374 (3d Cir. 2021). On November 2, 2023, Defendant Andreas Benjamin was involved in Plaintiff being taken into custody for technical violations of the conditions of Plaintiff's release, including failure to attend appointments at the probation office and failure to provide urine samples. (D.I. 9 at 6-7; 9-1.) At the time, Plaintiff was at an addiction treatment center in Wilmington, Delaware. (D.I. 9-1.) Plaintiff was receiving ongoing treatment for substance abuse, mental health conditions, and serious physical health conditions, including kidney cancer, seizures following brain surgery, and three hernias. (/d.) Plaintiff believes that being taken into custody constituted a violation of the Americans with Disabilities Act (ADA), given his serious medical conditions and ongoing treatment. (/d.) Plaintiff also believes that Defendant Jackson fabricated a report regarding Plaintiffs technical violations; Plaintiff maintains that he only missed appointments and

could not provide urine samples because of his medical conditions, which his doctors verified. (D.I. 9 at 7-8.) Furthermore, Plaintiff believes that Defendant Benjamin committed Health Insurance Portability and Accountability Act (HIPAA) violations, and violations of Plaintiff’s Fourth, Fifth, and Fourteenth Amendment rights, by calling “Christiana Care Hospital to obtain

information from Plaintiff[’s] medical record that he did not have authorization to” obtain. (Id. at 6.) On or about the same day, Plaintiff appeared before Defendant Tammy Jackson, who “served as the preliminary head hearing” in the parole board proceeding for the technical violations with which Plaintiff was charged. (Id. at 7.) During the hearing, Defendants Benjamin and Jackson allegedly violated Plaintiff’s equal protection and due process rights by not providing Plaintiff “with copies of mandatory documentations[,] so [Plaintiff] could prepare [his] defense against the false allegations.” (Id. at 6.) Defendant Jackson also allegedly violated Plaintiff’s due process and equal protection rights by failing to put her findings in writing and by denying Plaintiff’s requests to be represented by an attorney, to call witnesses, to testify on his own behalf,

to receive a copy of Defendant Benjamin’s written report, and to confront and cross examine his accuser, his own witnesses, and possibly also Defendant Jackson. (Id. at 7.) Plaintiff believes that members of the parole board, Defendants David Henderson, Dorothy Dillard, Herbert Konowitz, Steven Washington, and Margaret Henry, also violated Plaintiff’s due process rights because they “did nothing to question [the preliminary hearing,] prevent it[,] or correct it” on appeal or otherwise. (Id. at 8-9; see also D.I. 14 at 3-4.) Additionally, the acting chairwoman of the parole board, who is unnamed in Plaintiff’s pleadings, personally denied a request by Plaintiff to present documentary evidence. (D.I. 9 at 8.)

2 Since entering custody, Plaintiff believes that his due process and Eighth Amendment rights have been violated by Defendant Jacqueline Martin, “the head medical physician at H.R.Y.C.I.” for VitalCore, the medical services provider for the Delaware Department of Corrections (DDOC). (Id. at 9.) On May 13, 2024, Plaintiff had a seizure because medical staff

did not administer medication as required for five days, and Plaintiff sustained injuries to his head, arms, shoulders, neck, and back during the seizure. (Id. at 10.) Additionally, while in custody, Plaintiff’s kidney cancer and three hernias, one which is the “size of a cantalo[u]pe,” have caused him daily pain, and he has not received treatment needed for his medical conditions. (Id.) Plaintiff’s serious medical conditions have worsened during his time at HRYCI. (See D.I. 14.) Since entering custody, on various occasions, most recently in April 2025, Plaintiff has submitted sick call slips that received no response, and Plaintiff has submitted medical grievances regarding his declining health that were rejected as duplicative. (Id. at 1-2.) For this, Plaintiff faults several Defendants whom Plaintiff has identified as the “head decision makers” for DDOC and VitalCore. (Id. at 1.) Plaintiff faults Defendant Martin, mentioned above, and

Defendants Michael Records and Carolyn Ianni, the DDOC Bureau of Healthcare, Substance Abuse and Mental Health Services Chief and Medical Director, respectively. (Id.) III. SCREENING OF COMPLAINT A federal court may properly dismiss an action sua sponte under the screening provisions of 28 U.S.C. § 1915(e)(2)(B) if “the action is frivolous or malicious, fails to state a claim upon which relief may be granted, or seeks monetary relief from a defendant who is immune from such relief.” Ball v. Famiglio, 726 F.3d 448, 452 (3d Cir. 2013) (internal marks omitted); see also 28 U.S.C. § 1915(e)(2) (in forma pauperis actions). The Court must accept all factual allegations in

3 a complaint as true and take them in the light most favorable to a pro se plaintiff. See Phillips v. Cnty. of Allegheny, 515 F.3d 224, 229 (3d Cir. 2008). When a plaintiff proceeds pro se, the pleading is liberally construed, and the complaint, “however inartfully pleaded, must be held to less stringent standards than formal pleadings drafted by lawyers.” Erickson v. Pardus, 551 U.S.

89, 94 (2007). The legal standard for dismissing a complaint for failure to state a claim under § 1915(e)(2)(B) is identical to the legal standard used when ruling on Rule 12(b)(6) motions. Tourscher v. McCullough, 184 F.3d 236, 240 (3d Cir. 1999). A court reviewing the sufficiency of a complaint must take three steps: (1) take note of the elements the plaintiff must plead to state a claim; (2) identify allegations that, because they are no more than conclusions, are not entitled to the assumption of truth; and (3) when there are well-pleaded factual allegations, assume their veracity and then determine whether they plausibly give rise to an entitlement to relief. Connelly v. Lane Constr.

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Watson v. Benjamin, Counsel Stack Legal Research, https://law.counselstack.com/opinion/watson-v-benjamin-ded-2025.