Phillip Maurice Hicks v. Berkeley County, et al.

Summary

The United States District Court for the District of South Carolina adopted a magistrate judge’s Report and Recommendation and dismissed Phillip Maurice Hicks’s pro se action concerning alleged unconstitutional conditions of confinement at the Hill Finklea Detention Center. The court rejected objections concerning standing, municipal liability, deliberate indifference, supervisory liability, immunities, alleged human trafficking and attempted murder, and denial of further leave to amend. Federal claims were dismissed without issuance and service of process or further leave to amend, and the court declined supplemental jurisdiction over the state-law claims.

Holdings

1. A pro se plaintiff may not represent other inmates and lacked standing to assert their claims.
2. Berkeley County could not be held liable under § 1983 for alleged conditions at the detention center because South Carolina law places custody and control of the county jail with the sheriff.
3. Plaintiff failed to state a plausible Fourteenth Amendment deliberate-indifference claim because he did not allege that any defendant knew or should have known of his medical conditions and intentionally, knowingly, or recklessly failed to address a substantial risk of serious harm.
4. Plaintiff failed to state a supervisory-liability claim against the sheriff because he did not identify a subordinate or specific subordinate conduct creating a pervasive and unreasonable risk of constitutional injury.
5. Plaintiff failed to state a plausible claim against the fire marshal because he alleged no fire, gas poisoning, fire-code violation, personal involvement, or causal connection to a constitutional injury.
6. The § 1983 claims against the public defender failed because public defenders do not act under color of state law when performing traditional functions of counsel.
7. The claims against the family-court judge were barred by judicial immunity.
8. The human-trafficking allegations failed because Plaintiff lacked standing to assert claims for other inmates and any challenge to the denial of bond was an improper collateral attack barred by the Rooker-Feldman doctrine. The attempted-murder allegations also failed because Plaintiff did not connect any defendant to the alleged resuscitation treatment or plead a plausible cause of action.
9. The court properly denied a second opportunity to amend because further amendment would be futile.

Questions Presented

1. Whether the magistrate judge improperly engaged in fact-finding or weighed evidence during screening of the complaint.
2. Whether Plaintiff had standing to assert claims on behalf of other detainees.
3. Whether Berkeley County could be liable under § 1983 for conditions at a county detention center controlled by the sheriff under South Carolina law.
4. Whether Plaintiff plausibly pleaded a Fourteenth Amendment deliberate-indifference claim as a pretrial detainee.
5. Whether Plaintiff plausibly pleaded supervisory liability against the sheriff or deliberate indifference and personal involvement by the fire marshal.
6. Whether the § 1983 claims against the public defender were barred because she was not acting under color of state law.
7. Whether the claims against the family-court judge were barred by judicial immunity.
8. Whether Plaintiff's human-trafficking, attempted-murder, and related claims were plausibly pleaded or barred by standing and the Rooker-Feldman doctrine.
9. Whether the court properly denied further leave to amend as futile.

Disposition

dismissed