Leslie Washington v. Alycia Lewis and Correctional Officer Santiago

Summary

The United States District Court for the District of New Jersey grants Leslie Washington’s application to proceed in forma pauperis and screens his 42 U.S.C. § 1983 complaint. The court allows his Eighth Amendment excessive-force claim against Correctional Officer Santiago to proceed but dismisses without prejudice his supervisory-liability claims against Bayside State Prison Administrator Alycia Lewis for insufficient factual allegations.

Holdings

1. The allegations that Santiago sprayed Washington with pepper spray, pushed him down, and punched him after Washington struggled to comply because of a knee injury were sufficient at the screening stage for the excessive-force claim against Santiago to proceed.
2. A § 1983 supervisory-liability claim requires facts showing either that a policy, practice, or custom established by the supervisor directly caused the constitutional violation, or that the supervisor personally participated in, directed, or had contemporaneous knowledge of and acquiesced in the subordinate's conduct. Alleging only that grievances were submitted to a warden or administrator is generally insufficient without a plausible connection to the underlying violation.
3. Washington was granted leave to proceed in forma pauperis, but he remained responsible for the $350 filing fee, to be collected through the installment procedures required by the Prison Litigation Reform Act.

Questions Presented

1. Whether the allegations that Santiago used pepper spray, pushed Washington down, and punched him stated an Eighth Amendment excessive-force claim sufficient to proceed past screening.
2. Whether Washington stated an actionable § 1983 supervisory-liability claim against Lewis based on allegedly unconstitutional conditions of confinement and the submission of grievances.
3. Whether Washington was entitled to proceed in forma pauperis and, if so, how the Prison Litigation Reform Act filing fee should be assessed and collected.

Disposition

other