Anthony Trevon Kornegay v. Stg. Srgt. Christopher Gilbert, et al.

Summary

The United States District Court for the District of Hawaii dismissed Anthony Trevon Kornegay’s second amended 42 U.S.C. § 1983 complaint against three correctional officials. The court held that the claims were improperly joined and that the allegations failed to state plausible Fourteenth Amendment claims concerning safety, excessive force, and medical care. The dismissal was with prejudice, without leave to amend, and counted as a strike under 28 U.S.C. § 1915(g).

Holdings

1. Claims involving different defendants may be joined in one action only when the claims arise from the same transaction, occurrence, or series of transactions or occurrences and present a common question of law or fact. Kornegay's housing, excessive-force, and medical-care claims arose from distinct events and were improperly joined.
2. A pretrial detainee must plausibly allege that the defendant intentionally made a confinement decision, the resulting conditions placed the detainee at substantial risk of serious harm, the defendant failed to take reasonable available measures despite an objectively high risk, and that failure caused injury. Kornegay failed to plead sufficient facts showing substantial risk or objective unreasonableness.
3. A pretrial detainee must show that force purposely or knowingly used against him was objectively unreasonable. Kornegay failed to state a claim because he did not adequately describe what Sergeant Dardeen did, establish that Dardeen caused the injuries, or explain whether he resisted or complied with instructions.
4. A pretrial detainee asserting inadequate medical care must plausibly allege an intentional decision, a substantial risk of serious harm, failure to take reasonable available measures despite an objectively apparent risk, and causation. Mere negligence or disagreement with treatment is insufficient. Kornegay failed to state a claim against Nurse Hubbard.
5. Further leave to amend may be denied when amendment would be futile, including after repeated failure to cure identified pleading deficiencies. Because Kornegay had two prior opportunities and repeated guidance but alleged the same defects, the court denied further leave to amend.

Questions Presented

1. Whether Kornegay improperly joined claims arising from separate events and involving different defendants in one action.
2. Whether the allegations plausibly stated a Fourteenth Amendment threat-to-safety claim against Sergeant Gilbert.
3. Whether the allegations plausibly stated a Fourteenth Amendment excessive-force claim against Sergeant Dardeen.
4. Whether the allegations plausibly stated a Fourteenth Amendment inadequate-medical-care claim against Nurse Hubbard.
5. Whether further leave to amend should be denied as futile after two prior opportunities to amend.

Disposition

dismissed