Turner v. West County Detention Facility

Background

Curtis Turner, who was confined at the West County Detention Facility, filed a civil-rights complaint under 42 U.S.C. § 1983 against the facility and an unidentified deputy. His request to proceed without prepaying the filing fee was to be addressed in a separate order.

Turner alleged that on July 10, 2021, he asked a deputy for assistance while he was in his cell. After a hostile exchange, Turner alleged, the deputy entered the cell, ordered him to lie on his stomach, and kicked him in the mouth. Turner said the incident caused a busted lip and several broken teeth. He also alleged that the deputy searched his cell, found no contraband, and refused to obtain medical or dental treatment, other than bringing him a cup of water. Turner sought monetary damages.

Screening and Deficiencies

Because Turner was a prisoner seeking relief from a governmental entity or officer, the court was required to screen the complaint under 28 U.S.C. § 1915A. The court said that, read liberally, the allegations could support claims for excessive force and inadequate medical treatment. But the complaint did not provide enough information to proceed.

First, Turner had to explain his custody status when the incident occurred—whether he was a pre-arraignment or post-arraignment pretrial detainee or a convicted prisoner. That information was necessary to determine whether the claims arose under the Eighth Amendment, the Fourteenth Amendment, or, for a pre-arraignment detainee alleging excessive force, the Fourth Amendment standard discussed by the court.

Second, Turner had not identified the deputy who allegedly caused his injuries. The court noted that Turner referred to an appeal answered by “Sgt. Cogo & Lawson” and said he could review that appeal or seek information from those individuals to determine the deputy’s identity.

Third, Turner named the West County Detention Facility but made no specific allegations against it. The court explained that a local government may be liable under § 1983 when an official policy or custom causes a constitutional violation, but it cannot be held responsible merely because it employed the deputy. The court said Turner needed sufficient facts showing the required policy or custom and its connection to the alleged violation.

Ruling and Next Steps

Judge Beth Labson Freeman ordered that the complaint be DISMISSED with leave to amend. Turner had 28 days from the filing of the order to submit an amended complaint using the court’s form, including the case caption and number and the words “AMENDED COMPLAINT” on the first page. He had to answer all questions on the form. The amended complaint would replace the original complaint, and claims or defendants omitted from it would no longer be part of the case.

The court further ordered that failing to file an amended complaint within the deadline would result in dismissal of the action for failure to state a claim, without further notice to Turner.