Summary
The United States District Court for the District of Connecticut conducted an initial review of Romeo Elijah Martinez’s amended 42 U.S.C. § 1983 complaint alleging Eighth Amendment deliberate indifference to medical needs. The court allowed the claims against three medical defendants to proceed in their individual capacities, while dismissing without prejudice the official-capacity claims and the individual-capacity claims against the DOC Commissioner, deputy warden, and warden for lack of personal involvement. The court also issued service, discovery, and dispositive-motion deadlines.
Holdings
- At the initial-review stage, the allegations that Morozov, Zea, and Spano Lonis inadequately treated or delayed treatment for serious medical conditions and prolonged pain plausibly alleged deliberate indifference to serious medical needs.
- The amended complaint failed to allege the personal involvement of Quiros, Moore, and Martin because vague assertions that they knew about Martinez's medical problems and did nothing were insufficient.
- The official-capacity claims against all defendants were dismissed because the Eleventh Amendment bars monetary damages against state officials in their official capacities.
Questions Presented
- Whether the amended complaint plausibly alleged Eighth Amendment deliberate indifference to serious medical needs against Morozov, Zea, and Spano Lonis.
- Whether the amended complaint alleged the personal involvement of Quiros, Moore, and Martin sufficient to support individual-capacity damages claims under § 1983.
- Whether official-capacity claims seeking only monetary damages were barred by the Eleventh Amendment.
Disposition
other
Cases Cited (23)
- Giraldo v. Kessler, 694 F.3d 161, 164 (2d Cir. 2012)(followed)
- Ashcroft v. Iqbal, 556 U.S. 662, 678 (2009)(followed)
- Bell Atlantic Corp. v. Twombly, 550 U.S. 544, 570 (2007)(followed)
- Faber v. Metropolitan Life Insurance Co., 648 F.3d 98, 104 (2d Cir. 2011)(followed)
- Matheson v. Deutsche Bank National Trust Co., 706 F. App'x 24, 26 (2d Cir. 2017)(followed)
- Triestman v. Federal Bureau of Prisons, 470 F.3d 471, 474-75 (2d Cir. 2006) (per curiam)(followed)
- Wynder v. McMahon, 360 F.3d 73, 79 n.11 (2d Cir. 2004)(followed)
- Spavone v. New York State Department of Correctional Services, 719 F.3d 127, 138 (2d Cir. 2013)(followed)
- Hathaway v. Coughlin, 99 F.3d 550, 553 (2d Cir. 1996)(followed)
- Chance v. Armstrong, 143 F.3d 698, 702 (2d Cir. 1998)(followed)
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