Errick L. Young v. Alycia Lewis

Summary

The United States District Court for the District of New Jersey screened a pro se prisoner’s 42 U.S.C. § 1983 complaint alleging unconstitutional conditions of confinement at Bayside State Prison. The court granted in forma pauperis status and dismissed the complaint without prejudice because it alleged no facts establishing Defendant Alycia Lewis’s personal involvement or supervisory liability, while allowing thirty days to amend.

Holdings

1. A supervisor cannot be held liable under § 1983 solely because of the supervisor's position or respondeat superior; the plaintiff must allege facts showing personal involvement in the constitutional violation or that a policy or practice attributable to the supervisor directly caused the injury.
2. The complaint failed to state a plausible claim against Lewis because it did not allege sufficient facts establishing her personal involvement in, or responsibility for, the alleged Eighth Amendment violation.

Questions Presented

1. Whether the complaint stated a plausible Eighth Amendment conditions-of-confinement claim against the prison administrator under 42 U.S.C. § 1983.
2. Whether the complaint adequately alleged the defendant's personal involvement or supervisory liability under § 1983.
3. Whether the complaint should be dismissed during mandatory screening under 28 U.S.C. §§ 1915(e)(2)(B) and 1915A.

Disposition

dismissed