Johnson v. Hernandez

Background

Lewis W. Johnson, a state prisoner at the Correctional Training Facility, filed a complaint without a lawyer seeking compensatory and punitive damages under 42 U.S.C. § 1983. He was allowed to proceed without paying the usual filing fees. The original complaint alleged that Johnson tripped and fell at his prison job on September 27, 2018, suffering a severe injury because prison officials failed to maintain a safe work environment and did not identify or repair a tripping hazard.

A magistrate judge screened the original complaint under 28 U.S.C. § 1915A and dismissed it with leave to amend. The court instructed Johnson to identify each defendant’s specific actions, explain any supervisor’s involvement, provide more information about the hazard, and allege deliberate indifference rather than mere negligence. The court also explained that a prison-work claim under the Eighth Amendment requires allegations that the prisoner was compelled to perform physical labor beyond his strength, dangerous to his life or health, or causing undue pain.

Johnson timely filed an amended complaint. He named only Patricia Hernandez, identified as the Correctional Training Facility’s supervising correctional cook and his culinary supervisor. Johnson alleged that he tripped at the back door or culinary warehouse over a metal door sill raised approximately one-half inch above the floor. He alleged that the hazard had been reported to Hernandez, that one small repair was attempted but not completed, that Hernandez knew about the hazard before the incident, and that the hazard was repaired afterward.

Court’s Analysis

The court explained that an inmate seeking relief for injuries suffered in custody must show deliberate indifference under the Eighth Amendment or, in some circumstances, the Fourteenth Amendment. For an Eighth Amendment claim, the official must know of and disregard an excessive risk to the inmate’s health or safety. Negligence is not enough to support a § 1983 claim in the prison context.

The court concluded that Johnson’s allegations amounted to negligence. His allegations that he tripped over the raised door sill and that prison staff attempted but failed to complete a repair did not show deliberate indifference. The court also found that Johnson had not alleged that the requirements of his job caused the injury. Even if he had, the court said he did not allege that he was compelled to perform physical labor beyond his strength, dangerous to his life or health, or causing undue pain.

Disposition

The court found that the amended complaint did not cure the pleading deficiencies identified in the earlier dismissal order. It dismissed Johnson’s claims without prejudice for failure to state a claim upon which relief may be granted. The court stated that any negligence claim must be pursued in state court. It also certified that any appeal in which Johnson sought to proceed without paying fees would not be taken in good faith, directed the clerk to terminate pending motions as moot, and closed the file.