Levi Meyers v. Centurion, et al.

Summary

In this merit review order, the United States District Court for the Central District of Illinois dismissed Levi Meyers’s 42 U.S.C. § 1983 complaint without prejudice for failure to state a claim. The court found that the allegations did not adequately establish personal involvement by the individual defendants or a policy or practice supporting liability against Centurion, and granted Meyers 30 days to file an amended complaint.

Holdings

1. The complaint failed to state an actionable deliberate-indifference claim because its sparse allegations did not adequately connect the defendants' conduct to the required objective and subjective components of an Eighth Amendment medical-care claim.
2. The complaint failed to state a claim against the individual defendants because it did not allege facts showing that they personally participated in or caused the alleged constitutional deprivation.
3. The complaint failed to state a claim against Centurion because it did not allege that a Centurion policy or practice caused the injury, and Centurion could not be held liable solely for its employees' actions.

Questions Presented

1. Whether the complaint stated an Eighth Amendment deliberate-indifference claim based on the alleged requirement that Meyers use an inhaler to which he was allergic.
2. Whether the complaint adequately alleged personal involvement by the individual defendants.
3. Whether the complaint adequately pleaded municipal or corporate liability against Centurion based on a policy or practice rather than respondeat superior.
4. Whether the complaint should be dismissed under Federal Rule of Civil Procedure 12(b)(6) and 28 U.S.C. § 1915A.

Disposition

dismissed