Reynolds v. Unknown Names of Manufacturer or Responsible Individuals

Background

Brian Edward Reynolds, who was incarcerated and proceeding without a lawyer, sued defendants identified only as "Unknown Names of Manufacturer or Responsible Individuals." He alleged that, while incarcerated at the Federal Correctional Institution in Otisville between 2019 and 2022, his reflux medication was changed from Ranitidine to Famotidine without explanation. He also alleged that the Bureau of Prisons did not screen him for possible cancer. He claimed that defendants had knowingly poisoned him and acted with deliberate indifference to his life. He sought $1 million for stress and anxiety, $10 million in punitive damages, and immediate release from custody to monitor his health.

The court had previously allowed Reynolds to proceed without prepaying the filing fee. It reviewed the complaint under the statute requiring dismissal of a qualifying complaint that is frivolous, malicious, fails to state a claim, seeks money from an immune defendant, or lacks subject-matter jurisdiction. The court also applied the rule requiring a complaint to provide enough factual detail to make a claim plausible.

Federal Tort Claims Act

The court construed Reynolds's allegations about the Bureau of Prisons's failure to provide cancer screening as potentially asserting a claim under the Federal Tort Claims Act, which waives the federal government's immunity for certain tort claims. The proper defendant for such a claim is the United States, not an individual federal employee or agency.

The court dismissed any Federal Tort Claims Act claims for lack of subject-matter jurisdiction because Reynolds did not allege that he had filed an administrative claim for damages with the appropriate federal agency and received a final written determination. He also did not allege facts showing that six months had passed since filing an administrative claim. The court granted him 60 days to replead such a claim against the United States and directed him to allege exhaustion of the required administrative process.

Medical-Treatment Claim

The court construed Reynolds's allegations about the medication change and lack of cancer screening as potentially asserting a constitutional claim for deliberate indifference to serious medical needs by federal officials. A deliberate-indifference claim requires facts showing both that the medical condition or deprivation was objectively serious and that the defendant actually knew of and disregarded a substantial risk of serious harm. Negligence or a disagreement about medical treatment is not enough.

The court concluded that the complaint did not satisfy either requirement. It found that changing from one over-the-counter reflux medication to another was not shown to be poisoning or to pose an excessive risk to Reynolds's health. The complaint also did not allege facts showing that a Bureau of Prisons employee had the required culpable state of mind. The allegation that an official declined to screen Reynolds for cancer likewise did not include facts showing an excessive risk to his health.

The court did not decide whether Reynolds could pursue an implied damages remedy against federal officials because it was granting leave to amend. It granted him leave to replead a claim that Bureau of Prisons officials violated his constitutional right to adequate medical treatment.

Request for Release and Diversity Jurisdiction

Reynolds also sought immediate release from custody. The court said that the requested relief was ambiguous. To the extent he sought relief from conditions at the Illinois facility where he had previously been held, the claim was moot because he had been transferred. The court dismissed any such claims without prejudice, allowing Reynolds to refile them in the court covering the district where he was then incarcerated. The court explained that the proper respondent for a petition challenging the execution of a sentence would be the person holding the petitioner in custody, such as the warden of the current facility.

The court also found no diversity jurisdiction over possible state-law claims. Reynolds did not identify his pre-incarceration domicile, the entities he intended to sue, the nature of those entities, or relevant addresses. He also did not provide facts supporting a reasonable probability that his damages exceeded $75,000. The court therefore dismissed the action for lack of subject-matter jurisdiction on that basis.

Disposition and Leave to Amend

The court dismissed the complaint for failure to state a claim and for lack of subject-matter jurisdiction. It granted Reynolds 60 days to file an amended complaint. The amended complaint must identify the individuals allegedly involved, provide facts about what each defendant did or failed to do, describe the injuries, state facts about each defendant's state of mind, and specify the requested relief. Unknown defendants could be identified as John Doe or Jane Doe, but the court warned that doing so would not pause the applicable three-year limitations period.

The amended complaint would replace, rather than supplement, the original complaint. The court directed that it be submitted to the Pro Se Intake Unit, labeled as an amended complaint, and include docket number 24-CV-6854 (KMW). No summons would issue at that time. The court stated that failure to amend within the permitted period, absent good cause, would result in dismissal for failure to state a claim. It also certified that an appeal would not be taken in good faith and denied permission to proceed without prepaying fees for an appeal. The clerk was directed to keep the matter open until a civil judgment is entered.