Mays v. Doe

Background

Samuel D. Mays, representing himself, sued Correction Officers Geisha Falu and David Snell and inmate Brown under 42 U.S.C. § 1983, a federal civil-rights statute. Mays alleged that Falu and Snell knew he and Brown were subject to a no-contact order but intentionally placed Brown in the same holding unit. Mays alleged that Brown then charged him, pushed him against a wall, and struck him with the chains from Mays’s shackles. He alleged fractured ribs, a swollen back, and loss of sleep.

The court treated the allegations as true for purposes of deciding the officers’ motion to dismiss. Mays’s original complaint, later submissions, and amended complaint stated that the incident occurred at Orange County Jail on November 20, 2017, at approximately 8:30 a.m. The court also took notice of records showing that Mays had been convicted before the incident and applied the Eighth Amendment standard to his failure-to-protect claim.

Claims Against Falu and Snell

The State Defendants moved to dismiss under Federal Rules of Civil Procedure 8 and 12(b)(6). Rule 8 requires a complaint to provide a short and plain statement giving defendants fair notice of the claim. Rule 12(b)(6) permits dismissal when the allegations, even if accepted as true, do not plausibly show a right to relief.

The court rejected the Rule 8 argument because Mays identified a specific incident, identified the officers’ alleged conduct, described his injuries, and stated the basis for his requested compensation. The court also held that Mays plausibly alleged the officers’ personal involvement. According to the allegations, Falu knew about the no-contact order, told Snell about it, and the officers nevertheless placed Brown with Mays.

For a failure-to-protect claim under the Eighth Amendment, a prisoner must plausibly allege both a substantial risk of serious harm and that officials knew about and disregarded that risk. The court held that the alleged prior argument, resulting no-contact order, the officers’ knowledge of the order, and Brown’s subsequent attack were enough at the pleading stage. The court noted that later discovery might show different facts, but Mays had stated a claim that could proceed.

The court declined to decide the officers’ qualified-immunity argument because their briefing did not meaningfully apply that doctrine to the facts. It also did not address their argument concerning punitive damages because Mays had not specified what types of damages he sought.

Claim Against Brown

The court dismissed Mays’s claim against Brown under 28 U.S.C. § 1915(e)(2)(B), which requires dismissal of certain claims in a case where the plaintiff is allowed to proceed without prepaying the filing fee. Section 1983 applies only to conduct by a person acting under color of state law. Because Brown was an inmate and not a state actor, the court held that Mays could not pursue a § 1983 claim against him. The court dismissed the claims against Brown with prejudice.

Disposition

The court denied the State Defendants’ Motion to Dismiss. It dismissed with prejudice Mays’s claims against Brown, denied permission to appeal that dismissal without paying the filing fee because any appeal would not be taken in good faith, terminated Brown from the docket, and directed that a copy of the order be mailed to Mays. The court also set a status conference for January 15, 2020.