Carlos Coldon v. Rutherford County Sheriff's Office, et al.

Summary

The U.S. District Court for the Middle District of Tennessee granted Carlos Coldon leave to proceed in forma pauperis and conducted initial screening under the Prison Litigation Reform Act. The court dismissed the action for failure to state a claim, concluding that the allegations regarding the absence of wheelchair-accessible handrails did not support liability under 42 U.S.C. § 1983, the ADA, or the Rehabilitation Act. The court also denied the pending motion to appoint counsel as moot.

Holdings

1. The Rutherford County Sheriff's Office is not a proper Section 1983 defendant, although the claim was liberally construed as one against Rutherford County. Neither Rutherford County nor Rudd Medical Service could be held liable because the complaint did not plausibly allege that a policy or custom was the moving force behind the alleged deprivation.
2. The complaint did not state a plausible Eighth Amendment damages claim against Davis because Coldon did not allege that he suffered an injury caused by Davis's refusal to install handrails.
3. The request for transfer was moot because Coldon was transferred from the Rutherford County Jail and later released from custody.
4. The complaint failed to state a plausible failure-to-accommodate claim against the Rutherford County Sheriff's Office under Title II of the ADA or Section 504 of the Rehabilitation Act because it did not allege denial of a reasonable accommodation pursuant to a county policy, regulation, or other ruling because of disability.
5. Lieutenant Davis could not be held individually liable for damages under Title II or the Rehabilitation Act, and Rudd Medical Service was not a public entity subject to Title II merely because it contracted with the county to provide inmate healthcare.

Questions Presented

1. Whether the complaint plausibly stated a Section 1983 claim against Rutherford County, the Rutherford County Sheriff's Office, Rudd Medical Service, or Lieutenant Davis based on the lack of handrails and alleged deliberate indifference.
2. Whether Coldon's request for injunctive relief was moot after his transfer from the Rutherford County Jail and subsequent release.
3. Whether the complaint plausibly stated an ADA Title II or Rehabilitation Act failure-to-accommodate claim against the Rutherford County Sheriff's Office.
4. Whether Lieutenant Davis could be held individually liable under Title II of the ADA or the Rehabilitation Act, and whether Rudd Medical Service was a public entity subject to Title II.

Disposition

dismissed