Parker v. Santiago

Background

Keenan Parker, proceeding without a lawyer, sued C.O. Santiago, C.O. K. Breidenstein, L. Stanaway, and Captain Bey under 42 U.S.C. § 1983. He alleged violations of the Eighth and Fourteenth Amendments and alleged a conspiracy to violate his civil rights. Parker sought damages.

Parker alleged that, on December 14, 2020, at Green Haven Correctional Facility, Santiago conspired with a canine officer to make it appear that Parker possessed contraband. Parker said he attacked Santiago out of fear. He then alleged that he went into the yard, knelt, and placed his hands on his head, after which Breidenstein pepper-sprayed his eyes, face, and hair. Parker also alleged that Santiago and Breidenstein falsified an incident report, that Bey downloaded body-camera footage and allowed violations to proceed, and that Stanaway failed to advance his grievance. Parker claimed impaired vision, eye irritation, and emotional distress.

Motion and Legal Standards

The defendants moved to dismiss the amended complaint under Federal Rule of Civil Procedure 12(b)(6), which tests whether a complaint alleges enough facts to support a plausible legal claim. The court accepted the complaint’s factual allegations as true and viewed reasonable inferences in Parker’s favor. The court also applied the more flexible reading generally given to filings by people representing themselves.

Fourteenth Amendment Claims

The court dismissed Parker’s Fourteenth Amendment due-process claims against all defendants. It found that Parker did not allege facts showing that Stanaway personally violated his rights, that Bey denied him a procedural safeguard or affected his disciplinary process, or that Santiago and Breidenstein’s alleged false report was accompanied by a denial of procedures that would have allowed Parker to challenge it or by retaliation. The court stated that filing a false disciplinary report, by itself, does not establish a due-process violation.

Eighth Amendment Claims

The court denied the motion to dismiss Parker’s excessive-force claim against Breidenstein. Accepting Parker’s account as true, the court concluded that pepper-spraying an inmate who had stopped resisting, knelt, and placed his hands on his head plausibly alleged constitutionally excessive force and a malicious purpose.

The court granted the motion as to Parker’s excessive-force claims against Santiago, Bey, and Stanaway. Parker did not allege that Santiago used excessive force, and he did not allege that Bey or Stanaway were present, participated in, directed, or were personally involved in Breidenstein’s conduct. The court emphasized that damages under § 1983 require personal involvement and cannot be based only on supervisory responsibility.

The court also concluded that Parker had not plausibly alleged deliberate indifference to serious medical needs against any defendant. Parker did not identify a specific medical condition requiring treatment, an ignored request for care, a harmful delay, or facts showing that a defendant knew of and disregarded a serious health risk.

Conspiracy Claim

The court granted the motion to dismiss Parker’s § 1983 conspiracy claim. It found that Parker’s allegations that officers conspired to create the appearance of contraband and falsify a report were speculative and did not provide concrete facts showing an agreement, coordinated action, or specific acts taken to further an unlawful agreement.

Disposition and Amendment

The court granted the defendants’ motion to dismiss Parker’s Fourteenth Amendment due-process claims and Eighth Amendment deliberate-indifference claims against all defendants, while allowing Parker to amend those claims. The court deemed Parker’s Eighth Amendment excessive-force claims against Santiago, Bey, and Stanaway dismissed with prejudice, and deemed the § 1983 conspiracy claim against all defendants dismissed with prejudice. Parker’s only surviving claim was the Eighth Amendment excessive-force claim against Breidenstein.

The court granted Parker leave to file a second amended complaint addressing the due-process and deliberate-indifference claims by December 1, 2025. The court stated that, if Parker did not timely amend, the claims dismissed without prejudice would be deemed dismissed with prejudice. The opinion contains an internal inconsistency: its deliberate-indifference discussion says that claim was dismissed with prejudice, while the amendment section and conclusion treat the due-process and deliberate-indifference claims as dismissed without prejudice and subject to amendment.