Xavier Epps v. Becky Scott, et al.

Summary

The United States District Court for the District of New Jersey dismisses without prejudice Xavier Epps’s pro se 42 U.S.C. § 1983 complaint concerning alleged inadequate medical care while detained at Hudson County Correctional Center. The court finds insufficient allegations of supervisory liability, deliberate indifference, and personal involvement, and grants Plaintiff thirty days to file an amended complaint.

Holdings

1. A § 1983 plaintiff cannot impose supervisory liability merely because defendants are administrators; the complaint must allege personal involvement or identify a policy, practice, or custom that caused the constitutional injury and plead the required causal and knowledge elements. Epps's allegations against D'Antico and Casas did not satisfy that standard.
2. A pretrial detainee must allege a serious medical need and conduct by prison officials amounting to deliberate indifference. Epps failed to state such a claim against Dr. Benjamin, Baeza, and Smith because he did not provide sufficient facts about his medical condition, the treatment or medication required, the alleged emergency, or each defendant's awareness and deliberate indifference.
3. A § 1983 claim requires allegations that each defendant was personally involved in the alleged constitutional violation. Claims against Scott, Murrell, and Dr. Canigilia were properly dismissed because they were named in the caption but not implicated by any factual allegation.

Questions Presented

1. Whether the complaint plausibly alleged supervisory liability under 42 U.S.C. § 1983 against the administrators of Hudson County Correctional Center.
2. Whether the complaint plausibly alleged Fourteenth Amendment deliberate indifference to medical needs against Dr. Benjamin, Baeza, and Smith.
3. Whether claims against Scott, Murrell, and Dr. Canigilia failed because the complaint alleged no personal involvement by those defendants.
4. Whether the complaint should be dismissed without prejudice under the PLRA screening provisions.

Disposition

dismissed