Lee v. Department of Corrections

Background

Michael J. Lee brought a self-represented action under 42 U.S.C. § 1983, a federal law allowing claims against state actors who violate federal rights. He alleged that defendants were violating his constitutional rights by failing to provide means to protect him from contracting COVID-19 at the Vernon C. Bain Center. He described alleged overcrowding and unsafe conditions, including sleeping areas with detainees less than three to four inches apart and shared toilets, sinks, and showers. He initially sought relief for himself and other detainees, including improved conditions, reduced housing capacity, monetary damages, and release for detainees meeting certain criteria.

The court had previously severed the claims of the other individuals named in the complaint and amended complaint. The present action therefore proceeded only on Lee’s behalf. The opinion states that records appeared to indicate Lee was a pretrial detainee, but it directed him to allege his detention status in his next pleading.

Legal standards explained by the court

The court explained that a § 1983 claim requires allegations that a federal constitutional or statutory right was violated by a person acting under state law. For conditions-of-confinement claims, the objective element requires facts showing that the conditions, alone or together, created an unreasonable risk of serious harm to health or safety. The mental element differs depending on whether the person is a pretrial detainee or a convicted prisoner.

A convicted prisoner must allege that a correctional official knew about and disregarded an excessive risk to health or safety. A pretrial detainee must allege that the official intentionally imposed the condition or recklessly failed to use reasonable care to reduce a known or reasonably apparent excessive risk. The court also explained that negligence alone does not establish a federal constitutional violation under § 1983.

Order

The court determined that the amended complaint did not contain enough facts to state a claim and granted Lee leave to file a second amended complaint within 60 days. The new complaint must include only claims asserted on Lee’s own behalf and must provide a short, plain statement of the facts supporting each claim against each defendant. The court directed Lee, to the greatest extent possible, to identify relevant people and their titles, describe what each defendant did or failed to do, provide dates and locations, explain how the conduct violated his rights, describe his injuries, and state the relief sought.

The court specifically directed Lee to allege whether he was a pretrial detainee, the housing units where he was assigned, the particular conditions he challenged, facts suggesting a substantial risk of serious harm, and facts showing that defendants were deliberately indifferent to that risk. If he sought release, he also had to provide individualized facts supporting that remedy. Any defendant named by Lee had to be connected to the alleged violations through facts showing that defendant’s personal involvement.

Judge Stewart D. Aaron ordered the Clerk of Court to mail the order and a complaint form to Lee. The second amended complaint had to be submitted to the court’s Pro Se Intake Unit within 60 days, labeled as a “Second Amended Complaint,” and include the specified docket number. No further summons would issue at that time. If Lee failed to comply and could not show good cause, the court stated that it would recommend dismissal for failure to state a claim. The order itself did not rule on the ultimate merits of Lee’s constitutional claims.