Jonathan Kendrel Johnson v. Sgt. Lenored Longe, Sgt. J. Coleman, Sgt. Gentry, Jeffery Stevens

Summary

The United States District Court for the District of South Carolina adopted a magistrate judge’s Report and Recommendation concerning the screening of a pro se prisoner’s amended 42 U.S.C. § 1983 complaint. The court dismissed claims against Sgt. Lenored Longe and Jeffery Stevens with prejudice for lack of personal involvement or sufficient supervisory-liability allegations, while allowing claims against Sgt. J. Coleman and Sgt. Gentry to proceed. The order was entered on December 10, 2025, and provides notice of the right to appeal.

Holdings

1. When no specific objections are filed to a magistrate judge's Report and Recommendation, the district court need only determine whether the record contains clear error before adopting the recommendation.
2. A § 1983 claim requires an affirmative causal connection between the defendant's personal conduct and the alleged constitutional deprivation; Johnson failed to state such a claim against Longe.
3. A plaintiff may not establish § 1983 liability against a supervisor through a bare allegation of supervisory responsibility without facts showing personal involvement or satisfying the requirements for supervisory liability.
4. At the preliminary screening stage, Johnson's allegations against Coleman and Gentry, liberally construed, were sufficient to proceed beyond summary dismissal.

Questions Presented

1. Whether the district court should adopt the magistrate judge's Report and Recommendation in the absence of objections.
2. Whether Johnson stated a viable § 1983 claim against Longe when he alleged no affirmative causal connection between Longe's personal conduct and the alleged constitutional injuries.
3. Whether Johnson stated a viable § 1983 claim against Stevens based solely on Stevens's supervisory role without allegations of personal involvement or a legally sufficient basis for supervisory liability.
4. Whether Johnson's allegations against Coleman and Gentry were sufficient at the screening stage to avoid summary dismissal.

Disposition

other