King v. All Ramsey County Jail Nurses and Medical Staff

Background

Arron Scott King, Sr., a prisoner at the Washington County Jail, alleged that unnamed nurses and medical staff at the Ramsey County Jail were deliberately indifferent to his medical needs while he was detained there in November 2021. King alleged that he arrived unstable because he was not taking his mental-health medication, signed release forms allowing medical staff to obtain the medication, and nevertheless did not receive it during his three-week detention. He alleged that stopping the medication caused harmful effects that continued.

King sought $5 million in damages from “All Ramsey County Jail Nurses and Medical Staff.” The complaint did not name any specific medical professional.

Screening standard and analysis

Because King is a prisoner seeking relief from government personnel, the court reviewed the complaint before the case proceeded under 28 U.S.C. § 1915A. That law requires dismissal of a prisoner’s complaint, or part of it, if it is frivolous, malicious, fails to state a claim for relief, or seeks money from an immune defendant. The court applied the standard for whether the alleged facts plausibly state a claim, while construing the complaint liberally because King was not represented by a lawyer.

The court explained that a claim under 42 U.S.C. § 1983 requires a plaintiff seeking damages to show that a specific defendant personally acted unlawfully. The court found that King did not connect the alleged failure to provide medication to any identifiable person. Instead, he sued every nurse and medical-staff member at the jail without explaining why any particular person was being sued.

The court also rejected treating the complaint as a suit against the Ramsey County Jail or Ramsey County. The court stated that a county jail is not a legal entity that can be sued. Ramsey County could be sued under § 1983 only if King alleged that the county itself caused the constitutional violation through an official policy, an established unofficial custom, or a deliberately indifferent failure to train or supervise. King did not make such an allegation, including any allegation that the county had a policy of withholding mental-health medication from prisoners.

Ruling and disposition

The court held that King failed to state a claim under § 1983 against any specific identifiable defendant. It dismissed the action without prejudice under 28 U.S.C. § 1915A(b), meaning the dismissal did not bar refiling. The court did not decide whether the alleged failure to provide medication amounted to deliberate indifference.

The court also granted King’s application to proceed without paying the filing fee upfront. It ordered him to pay the unpaid $350 statutory filing fee in installments from his facility trust account and directed the Clerk of Court to notify the authorities at the institution where King was confined.