Jamison Fisher v. Henry County Jail et al.

Summary

The court screened Jamison Fisher’s 42 U.S.C. § 1983 complaint alleging denial of prescribed ADHD medication during detention at the Henry and Scott County Jails. It dismissed the complaint under 28 U.S.C. § 1915A(b)(1) because Fisher named jails rather than individual persons, denied his motions to add plaintiffs and waive the filing fee, and granted leave to file an amended complaint.

Holdings

1. The complaint failed to state a federal claim because a jail or correctional facility is not a suable person under § 1983, and the pleading did not identify individual defendants personally responsible for the alleged constitutional violation.
2. A pretrial detainee alleging inadequate medical care must plead that the medical condition was objectively serious, that the defendant acted purposefully, knowingly, or recklessly concerning the consequences, and that the defendant's actions were objectively unreasonable.
3. The motion to add plaintiffs was denied because § 1983 claims are personal to the injured party.
4. The motion to waive the filing fee or dismiss the case was denied because the court lacked statutory authority to waive the fee altogether, although payment in installments may be available to an in forma pauperis plaintiff.
5. Unrelated claims against unrelated defendants may not be joined in the amended pleading; multiple claims against a single defendant may be joined, but unrelated claims against different defendants may not.

Questions Presented

1. Whether the complaint stated a viable § 1983 claim when it named county jails rather than individual persons responsible for the alleged denial of medical care.
2. Whether the plaintiff could add other plaintiffs to his § 1983 action.
3. Whether the court had authority to waive the statutory filing fee altogether.
4. Whether unrelated claims and defendants could be joined in an amended pleading.

Disposition

dismissed