Wright v. Warden RMSC Doe

Background

Marcus Wright sued Warden RMSC John Doe and Grievance Supervisor Jane Doe, alleging violations of federal constitutional rights. The court treated the complaint as bringing claims under 42 U.S.C. § 1983, a statute that permits claims for constitutional violations by government officials. Wright alleged that, while detained at the Rose M. Singer Center from April 19, 2024 through July 2024, a Department of Correction mattress caused back, shoulder, and leg pain. Wright also alleged that the facility’s grievance committee prevented exhaustion of available remedies and acted retaliatorily. Wright sought $500,000 in damages and was proceeding without a lawyer.

The court had previously allowed Wright to proceed without paying filing fees in advance. It screened the complaint under the federal statutes governing review of prisoner complaints filed by people proceeding without prepayment of fees. Those statutes require dismissal of claims that are frivolous, fail to state a claim, seek money from an immune defendant, or fall outside the court’s subject-matter jurisdiction.

Conditions-of-Confinement Claim

Because Wright was a pretrial detainee, the court analyzed the mattress claim under the Fourteenth Amendment’s Due Process Clause. A conditions-of-confinement claim requires facts showing both that the condition posed an unreasonable risk of serious harm and that a correctional official intentionally imposed the condition or recklessly failed to address a known or reasonably knowable excessive risk.

The court held that Wright did not state this claim. Wright alleged pain but did not allege that the condition was serious enough to require medical attention or that medical care had been sought. Wright also did not allege facts showing that correctional staff knew or should have known of an excessive risk and disregarded it. The court therefore dismissed the claim for failure to state a claim. It granted leave to amend so Wright could provide facts about the medical condition and communications with medical staff.

Grievance-Access Claim

The court dismissed the claim concerning access to the facility’s grievance program. It held that denial of access to a prison grievance program, by itself, does not violate the Constitution under either the First Amendment or the Fourteenth Amendment. The court dismissed this claim for failure to state a claim under 28 U.S.C. § 1915(e)(2)(B)(ii).

Retaliation Claim

The court understood Wright’s allegation that correctional staff acted for retaliatory reasons as a possible First Amendment retaliation claim. Such a claim requires facts showing protected conduct, an adverse action that could deter a person of ordinary firmness, and a causal connection between the protected conduct and the adverse action.

The court dismissed the retaliation claim because Wright did not describe the protected speech or conduct that allegedly led to the denial of grievance access and did not allege facts showing a causal connection. The court granted leave to amend this claim with those details.

Personal Involvement

A § 1983 claim requires facts showing each defendant’s direct and personal involvement in the alleged constitutional violation. A supervisor cannot be held liable merely because a subordinate allegedly violated someone’s rights. The court dismissed the claims against the warden because Wright alleged no facts showing the warden’s personal involvement.

Disposition

Judge Laura Taylor Swain dismissed the complaint under 28 U.S.C. § 1915(e)(2)(B)(ii), with 30 days’ leave to replead. The amended complaint would replace, rather than supplement, the original complaint. The court instructed Wright to identify the people directly involved, describe what each person did or failed to do, provide relevant dates and locations, describe injuries, and state the requested relief. The court said that if Wright did not file an amended complaint within the allowed time, the Clerk would be directed to enter judgment.

The court certified that an appeal would not be taken in good faith and denied permission to proceed without prepaying fees for an appeal. It directed the Clerk to keep the matter open until a civil judgment was entered.