William A. Hudson v. S. Smallwood

CourtDistrict Court, N.D. Ohio
DecidedApril 22, 2026
Docket4:24-cv-02129
StatusUnknown

This text of William A. Hudson v. S. Smallwood (William A. Hudson v. S. Smallwood) is published on Counsel Stack Legal Research, covering District Court, N.D. Ohio primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
William A. Hudson v. S. Smallwood, (N.D. Ohio 2026).

Opinion

PEARSON, J.

UNITED STATES DISTRICT COURT NORTHERN DISTRICT OF OHIO EASTERN DIVISION

WILLIAM A. HUDSON, ) ) CASE NO. 4:24-CV-2129 Plaintiff, ) ) v. ) JUDGE BENITA Y. PEARSON ) S. SMALLWOOD, ) ) MEMORANDUM OF OPINION Defendant. ) AND ORDER ) [Resolving ECF No. 20]

Pending before the Court is Plaintiff William A. Hudson’s Motion for Leave to File Amended Complaint (ECF No. 20), which included the proposed amendments. ECF No. 20-1. Defendant opposes. ECF No. 21. Plaintiff separately filed the proposed Amended Complaint. ECF No. 22. For the reasons stated herein, Plaintiff’s Motion for Leave to File Amended Complaint (ECF No. 20) is granted and ECF No. 22 is accepted as Plaintiff’s First Amended Complaint. I. PROCEDURAL BACKGROUND Plaintiff filed this action against Defendant Sy Smallwood alleging an Eighth Amendment violation for failing to protect Plaintiff from inmate-on-inmate violence. ECF No. 1. Plaintiff alleges that Defendant was deliberately indifferent to a significant risk of harm when he allowed Plaintiff to be housed two cells away from another inmate, “Pack,” with whom Plaintiff did not get along and from whom Plaintiff requested separation out of fear of getting into an altercation. ECF No. 1. Defendant moved to dismiss the Complaint for failure to state a claim upon which relief may be granted. ECF No. 9. The Court denied the motion (ECF No. 14), concluding that Plaintiff sufficiently pled factual allegations to satisfy the objective and subjective prongs for a deliberate indifference claim. ECF No. 14 at PageID ##: 78–80. Plaintiff now moves for leave

to amend the complaint to include his state-law negligence claims. ECF No. 20; ECF No. 22. Defendant opposes, claiming that the proposed Amended Complaint would be futile because it cannot withstand a Rule 12(b) motion. ECF No. 21. II. LEGAL STANDARD “[A] party may amend its pleading only with the opposing party’s written consent or the court’s leave. The court should freely give leave when justice so requires.” FED. R. CIV. P. 15(a)(2). “Because Rule 15(a)(2) directs courts to ‘freely give leave when justice so requires,’ the rule embodies a ‘liberal amendment policy.’” Brown v. Chapman, 814 F.3d 436, 442–43 (6th Cir. 2016) (quoting Morse v. McWhorter, 290 F.3d 795, 800 (6th Cir. 2002)). “Despite this policy, denial may be appropriate when there is ‘undue delay, bad faith or dilatory motive on the

part of the movant, repeated failure to cure deficiencies by amendments previously allowed, undue prejudice to the opposing party by virtue of allowance of the amendment, futility of amendment, etc.’” Id. (quoting Foman v. Davis, 371 U.S. 178, 182 (1962)). The Sixth Circuit holds that it is inappropriate to dismiss even improperly pled claims with prejudice without affording the party an opportunity to correct pleading deficiencies. United States ex rel. Bledsoe v. Cmty. Health Sys., Inc., 342 F.3d 634, 644 (6th Cir. 2003). III. DISCUSSION The proposed Amended Complaint (ECF No. 22) contains several changes from the original complaint, including reformatting Plaintiff’s deliberate indifference claim and adding a new state-law negligence claim. Compare ECF No. 1, with ECF No. 22. Defendant argues that amendment would be futile because his state-law claims cannot withstand a Rule 12(b)(6) motion. Specifically, Defendant argues that he did not have actual or constructive knowledge of any unreasonable risk of harm Plaintiff faced by being placed on the same cell block as “Pack,”

claiming that Plaintiff’s kite request did not reference any threats or identify substantial risks of harm. ECF No. 21 at PageID #: 152–53. As explained below, the Court is satisfied that, on its face, the Amended Complaint (ECF No. 22) is sufficient. A. Rule 12(b)(6) Standard of Review. In resolving a motion to dismiss pursuant to Fed. R. Civ. P. 12(b)(6), the Court must take all well-pleaded allegations in the complaint as true and construe those allegations in a light most favorable to the plaintiff. See Erickson v. Pardus, 551 U.S. 89, 94 (2007) (citations omitted). A pleading must contain a “short and plain statement of the claim showing that the pleader is entitled to relief.” Ashcroft v. Iqbal, 556 U.S. 662, 677–78 (2009) (quoting Fed. R. Civ. P. 8(a)(2)). A cause of action fails to state a claim upon which relief may be granted when it lacks

“plausibility in th[e] complaint.” Bell Atl. Corp. v. Twombly, 550 U.S. 544, 564 (2007). A pleading that merely offers “labels and conclusions” or “a formulaic recitation of the elements of a cause of action will not do.” Id. at 555. Nor does a complaint suffice if it tenders “naked assertion[s]” devoid of “further factual enhancement.” Id. at 557. It must contain sufficient factual matter, accepted as true, to “state a claim to relief that is plausible on its face.” Id. at 570. “A claim has facial plausibility when the plaintiff pleads factual content that allows the court to draw the reasonable inference that the defendant is liable for the misconduct alleged.” Iqbal, 556 U.S. at 678 (citing Twombly, 550 U.S. at 556). On a motion under Rule 12(b)(6), the Court’s inquiry is generally limited to the content of the complaint, “although matters of public record, orders, items appearing in the record of the case, and exhibits attached to the complaint may also be taken into account without converting the motion to one for summary judgment.” Ira Svendsgaard & Assoc., Inc. v. AllFasteners USA,

LLC, No. 1:20 CV 328, 2021 WL 4502798, at *3 (N.D. Ohio Oct. 1, 2021) (Nugent, J.) (citing Gavitt v. Born, 835 F.3d 623, 640 (6th Cir. 2016)). B. Plaintiff’s State-Law Negligence Claims. To succeed on his state-law negligence claims, Plaintiff must demonstrate by a preponderance of the evidence that: (1) Defendant owed Plaintiff a duty; (2) Defendant breached that duty; and (3) the breach proximately caused Plaintiff’s injury. Ford v. Ohio Dep’t of Rehab. & Corr., 10th Dist. Franklin No. 05AP-357, 2006 WL 1390846, at *2 (Ohio Ct. App. May 23, 2006) (collecting cases). Although the Ohio Department of Rehabilitation and Corrections (“ODRC”) and its employees owe inmates a duty of reasonable care and protection from unreasonable risks, ODRC is not an insurer of inmate safety. Id. (citing Mitchell v. Ohio Dep’t

of Rehab. & Corr., 107 Ohio App.3d 231, 235 (Ohio Ct. App. 1995)). When there is inmate-on- inmate violence, a claim of negligence may arise “only whe[n] there was adequate notice of an impending attack.” Id. (citing Mitchell, 107 Ohio App.3d at 235). Therefore, Plaintiff must demonstrate that Defendant had actual or constructive notice of a potential attack. Id. at *4. Defendant relies on several Ohio cases to support his argument that he did not have adequate notice about an unreasonable risk of harm or assault to Plaintiff. In Elder v.

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Related

Foman v. Davis
371 U.S. 178 (Supreme Court, 1962)
Erickson v. Pardus
551 U.S. 89 (Supreme Court, 2007)
Bell Atlantic Corp. v. Twombly
550 U.S. 544 (Supreme Court, 2007)
Ashcroft v. Iqbal
556 U.S. 662 (Supreme Court, 2009)
Sidney Morse v. R. Clayton McWhorter
290 F.3d 795 (Sixth Circuit, 2002)
Brown Ex Rel. Estate of Brown v. Chapman
814 F.3d 436 (Sixth Circuit, 2016)
Baker v. State
502 N.E.2d 261 (Ohio Court of Appeals, 1986)
Mitchell v. Ohio Department of Rehabilitation
668 N.E.2d 538 (Ohio Court of Appeals, 1995)
David Gavitt v. Bruce Born
835 F.3d 623 (Sixth Circuit, 2016)

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