Roundtree v. Jane Doe 1

Background

Rashaun Roundtree, who was incarcerated at Clinton Correctional Facility when the order was issued, brought a self-represented lawsuit under 42 U.S.C. § 1983. That law allows a person to seek relief for violations of federal rights by a state actor. Roundtree alleged that, while detained at the Orange County Jail in August 2019, he developed a small lump that swelled to the size of a golf ball because of a methicillin-resistant Staphylococcus aureus infection. He alleged that he was not isolated, walked around with an open wound for two weeks, experienced severe pain, and suffered permanent scarring on his right knee and leg because of delayed wound care. He also alleged that jail medical staff did not test him for infection and instead tried different medications. He sought money damages and stated that a related state-court lawsuit remained pending.

The court had previously granted Roundtree permission to proceed without prepaying the filing fee. It reviewed the complaint under the screening rules for such lawsuits, which require dismissal of claims that are frivolous, malicious, legally insufficient, seek money from an immune defendant, or fall outside the court’s jurisdiction. The court also explained that self-represented complaints are read liberally but still must provide enough facts to make a claim plausible.

Court’s Analysis

Orange County Jail

The court dismissed Roundtree’s Section 1983 claims against Orange County Jail for failure to state a claim. It held that the jail is not a “person” that can be sued under Section 1983.

Orange County

The court found that Roundtree had not alleged facts showing that a policy, custom, or practice of Orange County caused a violation of his federal constitutional rights. The court granted Roundtree leave to file an amended complaint naming Orange County and alleging facts supporting municipal responsibility.

Individual defendants

The court stated that a Section 1983 claim for damages requires facts showing each defendant’s direct and personal involvement. A person cannot be held liable only because that person employed or supervised someone who allegedly violated Roundtree’s rights. Because Roundtree did not name individual defendants or describe their personal involvement, the court granted him leave to identify those defendants and provide supporting facts.

Disposition

The court granted Roundtree 60 days to file an amended complaint that would completely replace the original complaint. The court instructed him to include the relevant defendants, their actions or failures to act, approximate dates and locations, his injuries, and the relief sought. It stated that if he did not comply and could not show good cause, the complaint would be dismissed for failure to state a claim. The court also certified that an appeal would not be taken in good faith and denied permission to appeal without prepaying fees. The order was signed by Chief United States District Judge Laura Taylor Swain.