Wilson v. Ramsey County ADC

Background

Edward Wilson sued Ramsey County ADC and Peach Company under 42 U.S.C. § 1983. He alleged that, in 2019, while incarcerated at the Ramsey County Adult Detention Center, he ate a peach whose unusually large and sharp seed cut the inside of his throat. A jail nurse provided medical attention. Wilson described the incident as harrowing and sought $500 million in damages.

The magistrate judge recommended summary dismissal under 28 U.S.C. § 1915A, a statute requiring courts to screen certain complaints filed by incarcerated people. The recommendation also stated that Wilson’s application to proceed in forma pauperis, meaning without paying filing fees, should be denied because the complaint failed to state a claim. Wilson filed no objections.

Court’s Analysis

Because no objections were filed, the court reviewed the recommendation for clear error and adopted the magistrate judge’s findings. The court found no error in the analysis or conclusions.

As to the detention center and jail-related defendants, the court held that Wilson did not allege how the jail, any jail employee, or the political entity that employed the jail acted unlawfully. A claim that officials were deliberately indifferent to a serious risk requires allegations that they had subjective knowledge of a substantial risk of harm or disregarded an obvious harm. The complaint did not indicate that jail staff knew the peach had an unusually large and sharp seed. The court also noted that Wilson did not allege that jail personnel neglected or mistreated him after the injury.

As to Peach Company, the court held that the company was not subject to § 1983 liability because the complaint did not indicate that it was a state actor. Section 1983 generally permits claims against persons acting under state authority, not private entities lacking that status.

Disposition

The court ordered that the magistrate judge’s Report and Recommendation dated September 12, 2023, be adopted. It denied Wilson’s application for leave to proceed in forma pauperis and summarily dismissed the action under 28 U.S.C. § 1915A. The court directed that judgment be entered accordingly.