Watson v. Hamilton

District Court, W.D. Virginia·Decided August 20, 2025·No. 7:24-cv-00298·Unknown

Opinion

CLERK'S OFFICE U.S. DIST. COU AT ROANOKE, VA FILED IN THE UNITED STATES DISTRICT COURT August 20, 2025 FOR THE WESTERN DISTRICT OF VIRGINIA ,0088 4 AUSHN ROANOKE DIVISION Ss ReesOn aK KEVIN A. WATSON, ) ) Plaintiff, ) Case No. 7:24CV00298 ) V. ) OPINION AND ORDER ) M. HAMILTON, ET AL., ) JUDGE JAMES P. JONES ) Defendants. ) Kevin Watson, Pro Se Plaintiff; Laura Maughan, SANDS ANDERSON PC, Richmond, Virginia, for Defendant Dr. Fox; Ann-Marie White Rene and Caitlyn B. Switzer, OFFICE OF THE ATTORNEY GENERAL, CRIMINAL JUSTICE & PUBLIC SAFETY DIVISION, Richmond, Virginia, for all other Defendants. Plaintiff Kevin Watson, an unrepresented Virginia inmate, brings this civil rights action under 42 U.S.C. § 1983 against multiple defendants, alleging numerous violations of his constitutional rights and violations of the Religious Land Use and Institutionalized Persons Act (RLUIPA). Through counsel, the defendants have filed a Joint Motion to Dismiss, or in the alternative, Motion to Sever.! More specifically, the defendants move the court to dismiss without prejudice all claims

' Although represented by separate counsel, the defendants, acting jointly, submit this motion. Defendant Dr. Fox is represented by Laura Maughan, while Ann-Marie White Rene represents the other defendants: K. Almarode, the Commonwealth of Virginia, S. Day, Mr. C. Dotson, A. Duncan, M. E. Engelke (misidentified in the complaint as M. E. Englke), T. Fletcher, C. C. Gilbert, Grubb, L. N. Holbrook, N. Keeney, C. A. Manis, M. Owens, K.D. Ramey, Mr. D. Trent, Mr. White, and M. Hamilton. Defendant VitalCore Health Strategies (misidentified in the Complaint as Vital Core Health) has also filed a Motion to Dismiss, which has been addressed in a separate Opinion and Order.

and Defendants improperly joined with Watson’s first-in-time allegations as raised in his Complaint, in violation of Rule 20(a) of the Federal Rules of Civil Procedure.

In the alternative, the defendants move to sever the improperly joined claims to allow for Watson to re-file his claims in accordance with Rule 20 and the filing costs requirement of the Prison Litigation Reform Act (PLRA). Watson has responded,

making the motions ripe for consideration. Watson has also filed motions seeking disposition of the defendants’ motion. The defendants’ Joint Motion has liberally construed Watson’s Complaint as raising these claims:

Claim A: Defendant Hamilton retaliated against Watson by filing a disciplinary charge against him for refusing a skin injection TB test at Red Onion State Prison (ROSP), in violation of the Plaintiff’s First Amendment rights. Compl. 3, ECF No. 1.

Claim B: Defendant Ramey retaliated against Watson by finding him guilty at his disciplinary hearing for the charge of refusing the TB test at ROSP, in violation of Watson’s First Amendment rights. Id. at 8-9.

Claim C: Defendant White violated Watson’s RLUIPA and/or Fourteenth Amendment rights by failing to investigate and correct the fact that Watson had been charged and convicted of a disciplinary conviction for refusing the TB test. Id. at 13.

Claim D: Defendant Manis violated Watson’s RLUIPA and/or Fourteenth Amendment rights by failing to investigate and correct the fact that Watson had been charged and convicted of a disciplinary conviction for refusing the TB test. Id. at 15-16. Claim E: Defendant Dotson violated Watson’s RLUIPA rights by failing to provide for an alternative type of TB test that is not a “skin injection chemical test.” Id. at 18.

Claim F: Defendants Hamilton, Holbrook, Trent and Duncan conspired among themselves to violate Watson’s equal protection rights by refusing to provide him with an alternative to the TB skin injection test. Id. at 20.

Claim G: Defendant Engelke violated Watson’s RLUIPA and First Amendment rights by refusing to approve his request for a religious diet that is free from “harmful food.” Id. at 24-25.

Claim H: Defendants Fletcher, Owens, Almarode, and Keeney were deliberately indifferent to Watson’s medical needs when they “interfered with and failed to carry out” Watson’s medical diet order of no milk, in violation of his Eighth Amendment rights. Id. at 27.

Claim I: Defendants John and/or Jane Doe “interfered with” Watson’s medical diet order of no milk, in violation of his Eighth Amendment rights. Id. at 33.

Claim J: Defendant Dr. Fox was deliberately indifferent to Watson’s serious medical needs when he rescinded Watson’s no milk and no eggs diet order. Id. at 36-37.

Claim K: Defendant Owens retaliated against Watson in violation of the First Amendment by serving him eggs despite his no eggs diet order. Id. at 38.

Claim L: Defendant Dr. Fox retaliated against Watson in violation of the First Amendment by rescinding Watson’s no eggs and no milk diet order. Id. at 39-40.

Claim M: Defendant Hamilton violated Watson’s Fourth and Fourteenth Amendment rights by “manufactu[ring] false inculpatory evidence which led to [Watson’s] unreasonable seizure and to his prison disciplinary hearing guilty decision.” Id. at 41-42. Claim N: Defendants Hamilton, Gilbert, Grubb, Ramey, Day, White, and Manis violated Watson’s Fourteenth Amendment and/or RLUIPA rights by charging, convicting, and/or upholding Watson’s disciplinary conviction for refusing the TB skin injection test. Id. at 44-45.

Claim O: Defendants Fletcher, Owens, Almarode, and Keeney violated Watson’s rights under Article I, Section 9 of the Virginia Constitution by serving Watson milk despite his no milk diet order. Id. at 48.

Claim P: Defendant Dr. Fox violated Watson’s rights under Article I, Section 9 of the Virginia Constitution by rescinding Watson’s no milk and no egg diet order. Id. at 48-49.

Claim Q: The Commonwealth of Virginia breached a RLUIPA contract with the federal government, “the Defendant Healthcare Provider and [Watson as a] third-party beneficiary” when Watson was not provided an alternative to the TB skin injection test. Id. at 49-53.

Mem. Supp. Joint Mot. Dismiss or Sever 4-6, ECF No. 27 (citation modified).2

Courts have uniformly held that parties are misjoined when they fail to meet the standard for permissive joinder in Federal Rule of Civil Procedure 20(a). Hanna v. Gravett, 262 F. Supp. 2d 643, 647 (E.D. Va. 2003) (collecting cases). Rule 20(a) states that persons may be joined as defendants in one action if they satisfy two conditions: (1) “any right to relief is asserted against them jointly, severally, or in

2 The defendants’ construction of Watson’s claims in the Complaint, and my adoption of that construction in this Order, do not reflect any agreement by the defendants or by me that Watson’s allegations, so grouped, state cognizable claims for relief against the listed defendants. the alternative with respect to or arising out of the same transaction, occurrence, or series of transactions or occurrences” and (2) “any question of law or fact common

to all defendants will arise in the action.” Fed. R. Civ. P. 20(a)(2)(A) – (B). Thus, where claims arise out of different transactions and do not involve all defendants, joinder of the claims in one lawsuit is not proper. Moore v. Squire, No. 7:23-CV-

00439, 2023 WL 5095696, at *1 (W.D. Va. Aug. 9, 2023). The defendants argue that Watson’s claims are misjoined, but they assert that his claims, regrouped into three separate lawsuits, could satisfy Rule 20(a).

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Watson v. Hamilton, (W.D. Va. 2025).

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