Bryant Davis a/k/a Bryant Davidson v. Sergeant Smith, et al.

Summary

The United States District Court for the District of Maryland granted Defendants’ motion to dismiss or, alternatively, for summary judgment, in a § 1983 action brought by Bryant Davis concerning alleged denial of medical care while housed in segregation. The court also granted Defendants’ motion to seal exhibits containing sensitive medical and behavioral health information. Davis’s claims were dismissed without prejudice because he failed to exhaust available administrative remedies under the Prison Litigation Reform Act.

Holdings

1. Claims against state correctional employees in their official capacities are barred by Eleventh Amendment immunity because such claims are treated as claims against the State, and Maryland has not waived that immunity for § 1983 claims.
2. A prisoner may not bring a § 1983 action concerning prison conditions until available administrative remedies have been properly exhausted. Because Davis did not file or pursue an administrative grievance concerning the alleged denial of medical care, his claims were unexhausted and had to be dismissed without prejudice.
3. The court granted defendants' motion to seal selected medical records because the records contained sensitive medical and behavioral-health information, the request was not overly broad, and the records were unnecessary to resolve the case.

Questions Presented

1. Whether Davis's claims against defendants in their official capacities are barred by Eleventh Amendment immunity.
2. Whether Davis exhausted the administrative remedies required by the Prison Litigation Reform Act before bringing his § 1983 claims.
3. Whether defendants' medical and behavioral-health exhibits should remain under seal.

Disposition

dismissed