Daniel Neil Jackson v. D. Dameron, RN; Dr. K. Smith

Summary

The United States Court of Appeals for the Fourth Circuit affirmed the district court’s judgment in favor of prison medical defendants in Daniel Jackson’s § 1983 action. The court held that the district court properly construed the pro se complaint as asserting Eighth Amendment deliberate-indifference claims and was not required to independently identify an Americans with Disabilities Act accommodation claim from the allegations. Judge Floyd dissented.

Holdings

1. A district court must liberally construe a pro se prisoner's complaint and raise the strongest arguments suggested by the factual allegations, but it is not required to invent every conceivable claim or act as the litigant's legal advocate.
2. The district court did not err by construing Jackson's complaint as asserting Eighth Amendment deliberate indifference rather than an ADA failure-to-accommodate claim.
3. The court assumed without deciding that de novo review applied to the district court's determination of what claims Jackson's factual allegations presented.

Questions Presented

1. Whether the district court properly construed Jackson's pro se prison complaint as asserting an Eighth Amendment deliberate-indifference claim rather than also identifying an ADA failure-to-accommodate claim.
2. What standard of review applies when reviewing a district court's identification of legal claims in a pro se prisoner's complaint.

Disposition

affirmed