Williams v. CoreCivic of Tennessee, LLC

CourtDistrict Court, W.D. Tennessee
DecidedMarch 28, 2025
Docket1:24-cv-01074
StatusUnknown

This text of Williams v. CoreCivic of Tennessee, LLC (Williams v. CoreCivic of Tennessee, LLC) 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
Williams v. CoreCivic of Tennessee, LLC, (W.D. Tenn. 2025).

Opinion

IN THE UNITED STATES DISTRICT COURT FOR THE WESTERN DISTRICT OF TENNESSEE EASTERN DIVISION

CHRISTINE WILLIAMS, as ) Administrator ad Litem for the Estate ) of Sylvainus Cole, III, Deceased, ) ) Plaintiff, ) ) v. ) Case No. 1:24-cv-01074-JDB-jay ) CORECIVIC OF TENNESSEE, LLC, ) CORECIVIC, INC., ALEXIE PRUITT, ) CHERTERICA NEAL and JOHN DOES, ) ) Defendants. )

ORDER GRANTING DEFENDANTS’ MOTION TO DISMISS AMENDED COMPLAINT

Before the Court is the October 8, 2024, motion of the Defendants, CoreCivic of Tennessee, LLC, CoreCivic, Inc., Alexie Pruitt, and Cherterica Neal, to dismiss the Plaintiff’s, Christine Williams, as Administrator ad Litem for the Estate of Sylvanius Cole, III, Deceased, amended complaint. (Docket Entry (“D.E.) 24.) Plaintiff has responded (D.E. 27) and Defendant replied (D.E. 28). For the following reasons, Defendant’s motion is GRANTED. I. FACTUAL BACKGROUND1 Sylvanius Cole, III was an inmate in the custody of Whiteville Correctional Facility (the “WCF”) before he tragically passed away on April 3, 2023. (D.E. 20 at PageID 363, 365, 369–

1 The following facts are derived from Plaintiffs’ amended complaint (D.E. 20) and are accepted as true for purposes of this motion. See Ashcroft v. Iqbal, 556 U.S. 662, 678 (2009); Bell Atl. Corp. v. Twombly, 550 U.S. 544, 555–56 (2007); see also Parry v. Mohawk Motors of Mich., Inc., 236 F.3d 299, 306 (6th Cir. 2000) (citing In re Atlas Van Lines, Inc., 209 F.3d 1064, 1067 (8th Cir. 2000)) (explaining that when a plaintiff files an amended complaint, the amended complaint is the controlling pleading). 70.) The WCF is a private prison owned, operated, maintained, managed, and controlled by Defendants CoreCivic of Tennessee, LLC and CoreCivic, Inc. (collectively, “CoreCivic”). (Id. at PageID 363.) CoreCivic has statutory authority to operate private prisons in the State of Tennessee pursuant to the Private Prison Contracting Act of 1986, Tenn. Code Ann. §§ 41-24-101 through 41-24-119, and is required to operate the the WCF in compliance with Tennessee law and their

contractual obligations. (Id. at PageID 364.) Plaintiff alleges that CoreCivic acted under the color of state law at all times relevant to this action. (Id.) Defendants Alexie Pruitt, correctional officer at the WCF, Cherterica Neal, correctional officer at the WCF, and John Does were employed by CoreCivic at the time of Cole’s death and were acting under the color of state law and in the course and scope of their employment with the WCF. (Id.) On April 3, 2023, at approximately 5:19 p.m., Defendant Pruitt escorted Roderickus Tate to cell 206 in the KD pod and secured him there with Cole without Tate undergoing a proper search. (Id. at PageID 369.) Consequently, Tate was able to bring fentanyl into the cell; fentanyl that Plaintiff alleges “was brought into the prison by another person due to the lack of sufficient staffing

and searches at the WCF.” (Id.) For the next hour and a half no cell checks, security sweeps, or head counts were conducted of KD pod. (Id.) At some point during that time, Cole ingested the fentanyl “and began to have an adverse reaction cause by an overdose.” (Id.) Neal entered KD Pod at approximately 6:50 p.m. and heard inmates yelling in the upper tier. (Id.) As Neal approached cell 206, she saw Cole on the floor and Tate attempting to administer chest compressions. (Id.) At 6:56 p.m. Neal called a medical code for a possible overdose. (Id. at PageID 370.) After calling the code, she did not administer first aid or medical care to Cole. (Id.) Medical staff arrived at the cell about three minutes later and immediately administered Naloxone (“Narcan”) and began CPR. (Id. at PageID 368, 370.) Despite these efforts, Cole remained unresponsive and was taken to the WCF medical clinic. (Id. at PageID 370.) At some point thereafter, emergency medical services were contacted and Cole was transported to Bolivar General where he died from fentanyl and tramadol toxicity. (Id. at PageID 365, 369.) During his time at the WCF, Cole “was addicted to drugs and had essentially unfettered access to illegal substances.” (Id. at PageID 365.) Plaintiff alleges that Defendants knew of the

“wide availability and accessibility” that the WCF inmates had to these substances, and, specifically, of Cole’s addiction and access to these illegal substances. (Id.) The deceased would routinely refuse periodic drug tests, would test positive for illegal drugs when tests were administered, and suffered a prior opioid drug overdose while in JE pod on March 18, 2023. (Id. at PageID 365, 370.) After the March 18 overdose and following a denial of admittance into the withdrawal management unit, Cole was moved to KD pod and placed on the waitlist for a Therapeutic Community program. (Id. at PageID 368, 370.) Plaintiff submits that Corecivic did not investigate the source of the drugs on which he overdosed. (Id. at PageID 381.) Plaintiff attributes Cole’s death to CoreCivic engaging in a purposeful staffing shortage,

“inadequate supervision, inadequate medical care, and improper inmate segregation practices,” in order to maximize profits. (D.E. 20 at PageID 376.) According to the complaint, CoreCivic’s insufficient staffing led to an increased presence of illegal substances in the WCF, “because existing staff was not sufficient to conduct proper security searches of individuals entering the prison, including searches of corrections staff.” (Id. at PageID 366–67.) In the period immediately preceding Cole’s death, March and April of 2023, the WCF was allegedly understaffed and overcrowded, with “nearly 40% of critical corrections positions vacant,” while at “101% of its operational capacity for inmates.” (Id. at PageID 367–68.) The staffing shortage contributed to a lack of searches, sweeps, and inspections within the prison, a decrease in drug rehabilitation and prevention programs within the facility, and the inability for staff to timely respond to and address emergencies. (Id. at PageID 367–68.) The lack of searches and sweeps provided inmate Tate the opportunity to bring fentanyl into his shared cell with Cole, which, combined with CoreCivic’s failure to provide Narcan to corrections officers at the WCF, ultimately led to Cole’s overdose and death. (Id. at PageID 371–72, 379.)

Plaintiff refers to three performance audit reports on the WCF in her complaint, issued in 2017, 2020, and 2023. (Id. at PageID 372.) These audits, conducted by the Tennessee Comptroller of the Tennessee Department of Correction, detailed the WCF’s staffing shortages. (Id. at PageID 372, 375.) Specifically, the 2017 audit “found that 79 officers were required to cover 17 positions during a shift, but on average the facility only provided 57 officers per shift.” (Id. at PageID 375.) The 2020 audit report stated that “low staffing coupled with frequent overtime impacted management’s ability to provide safe and secure facilities, especially in emergencies.” (Id. at PageID 372.) The audit found that there were 26 vacant correctional officer positions and 75 overall vacant positions. (Id. at PageID 373.) Plaintiff maintains that these incidents of

understaffing demonstrate that CoreCivic “had a custom and practice of being deliberately indifferent to the health and safety of inmates, including [Cole].” (Id. at PageID 376.) Finally, Plaintiff brings claims against Pruitt and Neal in their individual capacities.

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Bluebook (online)
Williams v. CoreCivic of Tennessee, LLC, Counsel Stack Legal Research, https://law.counselstack.com/opinion/williams-v-corecivic-of-tennessee-llc-tnwd-2025.