Stephen Willett v. Lincoln Correctional Center, et al.

Summary

The court conducted a merit review under 28 U.S.C. § 1915A of Stephen Willett’s amended § 1983 complaint concerning injuries allegedly caused by a malfunctioning trash compactor at Lincoln Correctional Center. The court allowed an Eighth Amendment conditions-of-confinement claim to proceed against Maintenance Supervisor Ronnie Boggs, dismissed Lincoln Correctional Center with prejudice, and dismissed the remaining defendants without prejudice. The order also addressed service, pleading, discovery, and medical-record procedures.

Holdings

1. The allegations were sufficient to proceed against Boggs on an Eighth Amendment conditions-of-confinement claim because Willett alleged that Boggs knew of the trash compactor's excessive hydraulic-oil leak and nevertheless instructed him to continue using it.
2. Lincoln Correctional Trash Company was not a proper § 1983 defendant on the allegations presented and was dismissed without prejudice.
3. Lincoln Correctional Center was not a person amenable to suit under § 1983 and, as a state agency, was protected by Eleventh Amendment immunity from a suit for money damages; it was dismissed with prejudice.
4. The claims against Farrington and Kennedy failed because the amended complaint contained no specific allegations against them and § 1983 does not impose liability based solely on supervisory status; they were dismissed without prejudice.

Questions Presented

1. Whether the amended complaint plausibly alleged an Eighth Amendment conditions-of-confinement claim against Maintenance Supervisor Ronnie Boggs.
2. Whether Lincoln Correctional Trash Company was a proper defendant under 42 U.S.C. § 1983.
3. Whether Lincoln Correctional Center was a person subject to suit under § 1983 and whether Eleventh Amendment immunity barred a damages action against it.
4. Whether the claims against Warden Tiona Farrington and Lieutenant Kennedy failed because the amended complaint alleged no personal participation and § 1983 does not impose respondeat superior liability.

Disposition

other