Wattleton v. Doe

Background

David E. Wattleton, an inmate at the Federal Medical Center in Rochester, filed this action without a lawyer against one defendant identified as “John Doe” and “Captain.” Wattleton alleged that the defendant was an employee of the facility and was deliberately indifferent to a substantial risk that another inmate would seriously harm him. He also alleged that the defendant failed to allow him “full privileges” in a unit building. Wattleton described the claim as one against the defendant in the defendant’s official capacity and did not refer to an individual-capacity claim.

Wattleton sought declaratory and injunctive relief—an order directing the defendant to stop encouraging threatening or aggressive behavior toward him—as well as compensatory damages for emotional distress. He also applied to proceed without paying filing fees.

Magistrate Judge’s Recommendation and Objection

Magistrate Judge Leo I. Brisbois recommended denying the application to proceed without paying filing fees and dismissing the action with prejudice. He concluded that Wattleton’s official-capacity claim was treated as a claim against the United States. Because the United States generally has sovereign immunity, meaning protection from lawsuits unless Congress has waived that protection, the magistrate judge determined that the court lacked subject-matter jurisdiction over the claim.

Wattleton objected that the defendant was not entitled to qualified immunity and argued that he had raised a genuine dispute about whether he faced an objectively serious risk of harm. He did not address the sovereign-immunity issue.

District Court’s Analysis

The district court agreed that an official-capacity suit against a federal employee is effectively a suit against the federal government. It also agreed that sovereign immunity had not been waived for Wattleton’s claim seeking monetary damages under Bivens, a judicially recognized claim for certain constitutional violations by federal officials. Bivens claims for damages may be brought against federal officials in their personal capacities, but not in their official capacities. The court therefore held that it lacked subject-matter jurisdiction over the monetary-relief claim.

The court disagreed with the magistrate judge’s conclusion that sovereign immunity also barred the requested injunctive and declaratory relief. Relying on the Administrative Procedure Act and Eighth Circuit precedent, the court held that it had subject-matter jurisdiction over Wattleton’s direct constitutional claims to the extent he sought nonmonetary relief.

The court nevertheless dismissed the nonmonetary claims under Federal Rule of Civil Procedure 12(b)(6), which permits dismissal when a complaint does not state a legally sufficient claim. The court found that Wattleton’s allegations were largely conclusory and did not provide specific facts showing an objectively serious risk of injury, the defendant’s actual knowledge of such a risk, or a sufficient connection between the defendant and the alleged constitutional violations.

Disposition

The court adopted the Report and Recommendation as modified. It overruled Wattleton’s objection, denied his application to proceed without paying filing fees as moot, and dismissed the action without prejudice. The dismissal rested on lack of subject-matter jurisdiction for the monetary-relief claim and failure to state a claim for the nonmonetary relief.