Cornel Myers v. Angel Quiros, et al.

Summary

The United States District Court for the District of Connecticut conducted an initial review of Cornel Myers’s pro se 42 U.S.C. § 1983 complaint concerning alleged retaliation, prison conditions, medical care, and placement in restrictive housing. The court dismissed the complaint without prejudice for failure to allege defendants’ personal involvement and failure to state plausible constitutional claims, while allowing Myers to file an amended complaint by February 19, 2026.

Holdings

1. A plaintiff seeking damages under 42 U.S.C. § 1983 must allege facts establishing each defendant's personal involvement in the alleged constitutional violation, including supervisory officials; Myers failed to do so.
2. A First Amendment retaliation claim requires protected speech or conduct, adverse action, and a causal connection between the protected conduct and the adverse action; Myers's allegations did not plausibly satisfy those requirements.
3. A conditions-of-confinement claim requires an objectively sufficiently serious deprivation or substantial risk of serious harm and a defendant's subjective deliberate indifference; Myers's allegation that he was placed in a filthy cell was insufficiently specific to state a plausible claim.
4. A medical deliberate-indifference claim requires actual deprivation of adequate medical care in response to a sufficiently serious medical condition and subjective recklessness by the defendant; Myers's allegation that he lost consciousness and was hospitalized did not state a plausible claim.
5. A procedural due process claim concerning restrictive housing requires a protected liberty interest and constitutionally sufficient procedures; Myers failed to allege facts concerning the conditions, duration, or procedures of his confinement.
6. Claims for injunctive and declaratory relief must be asserted against officials in their official capacities and require an ongoing constitutional violation; Myers's claims were unavailable against defendants sued only individually, moot as to officials at the facility he left, or unsupported by allegations of an ongoing violation.
7. A state agency is not a person subject to suit under 42 U.S.C. § 1983; therefore, the claims against John Dempsey Hospital were dismissed.

Questions Presented

1. Whether the complaint adequately alleged the personal involvement of the named defendants in constitutional violations for purposes of a damages claim under 42 U.S.C. § 1983.
2. Whether the complaint plausibly stated a First Amendment retaliation claim based on Myers's hunger strike.
3. Whether the complaint plausibly stated an Eighth Amendment conditions-of-confinement claim.
4. Whether the complaint plausibly stated an Eighth Amendment deliberate-indifference-to-medical-needs claim.
5. Whether the complaint plausibly stated a Fourteenth Amendment procedural due process claim based on placement in restrictive housing.
6. Whether Myers could obtain injunctive or declaratory relief against defendants sued only in their individual capacities and against officials at a facility where he was no longer housed.
7. Whether John Dempsey Hospital, as a state agency, was a person subject to suit under § 1983.

Disposition

dismissed