Frederick Allen Barnes v. Alex Downing, et al.

Summary

In this prisoner civil-rights action under 42 U.S.C. § 1983, the court reviewed the complaint under 28 U.S.C. § 1915(e)(2). The court dismissed the official-capacity claims and the individual-capacity claims against several defendants, but found plausible Eighth Amendment failure-to-protect claims against Alex Downing and Case Manager Lawson and directed service on those defendants.

Holdings

1. Official-capacity claims for damages against the defendants, who were alleged to be employees of a Missouri state agency, were dismissed without prejudice because such claims are treated as claims against the state or its agency and are barred by Eleventh Amendment immunity; the officials are also not persons subject to damages liability under § 1983 in their official capacities.
2. The complaint plausibly stated individual-capacity Eighth Amendment failure-to-protect claims against Downing and Lawson, and the court directed that they be served.
3. The complaint failed to state plausible individual-capacity § 1983 claims against Walter, Precythe, Price, Glore, Davis, Brown, Lindell, and Roach, so those defendants were dismissed without prejudice.

Questions Presented

1. Whether the complaint stated plausible Eighth Amendment failure-to-protect claims against Downing and Lawson.
2. Whether the complaint stated plausible individual-capacity § 1983 claims against Walter, Precythe, Price, Glore, Davis, Brown, Lindell, and Roach.
3. Whether official-capacity claims for damages against Missouri Department of Corrections employees were barred by sovereign immunity and the Eleventh Amendment.
4. Whether the complaint adequately pleaded personal involvement rather than relying on supervisory or respondeat superior liability.

Disposition

other