Grayson v. Lynch

Summary

The court screens a state prisoner’s third amended complaint under 42 U.S.C. § 1983 alleging Eighth Amendment violations. It finds a cognizable conditions-of-confinement claim against defendant Vang based on prolonged exposure to extremely cold temperatures, but concludes that the remaining claims and allegations against Sergeant Nelson fail to state a claim. The court gives plaintiff thirty days to proceed on the cognizable claim or file a fourth amended complaint.

Holdings

1. Yes. Grayson's allegations that Vang knowingly left him in prolonged freezing temperatures while aware that he was in pain and seeking help sufficiently alleged deprivation of adequate heating and deliberate indifference to a substantial risk of serious harm.
2. No. The complaint failed to state a claim against Nelson because it did not indicate that Nelson personally participated in any wrongdoing.
3. No. The allegations that Vang said he had called for a clinician, but that no clinician arrived, did not plausibly show that Vang failed to take reasonable steps to address a serious risk to Grayson's mental-health needs.
4. No. The complaint did not state a claim against Vang for placement in the holding cell because it alleged that Diaz and Vazquez, neither of whom was a named defendant, placed Grayson there.

Questions Presented

1. Whether the third amended complaint stated a cognizable Eighth Amendment conditions-of-confinement claim against Vang based on prolonged exposure to extremely cold temperatures.
2. Whether the complaint stated an Eighth Amendment deliberate-indifference claim against Nelson when it did not allege Nelson's personal participation in the alleged wrongdoing.
3. Whether Vang's alleged failure to obtain an additional mental-health clinician stated an Eighth Amendment claim.
4. Whether the allegations supported an Eighth Amendment claim against Vang for placing Grayson in the outside holding cell when the complaint alleged that Diaz and Vazquez placed him there.

Disposition

other