Ricardo Ray Anguiano v. Ashly Ketcher, et al.

Summary

The United States District Court for the Eastern District of Oklahoma screened Ricardo Ray Anguiano’s 42 U.S.C. § 1983 complaint as a pretrial detainee and found that it failed to state a plausible claim for relief. The court dismissed the complaint without prejudice under 28 U.S.C. § 1915A(b)(1), granting leave to file an amended complaint within twenty-one days.

Holdings

1. A prisoner civil-rights complaint must be dismissed at screening when its factual allegations fail to plausibly support a cognizable claim for relief.
2. The complaint failed to state a plausible Fourteenth Amendment claim because it did not allege a qualifying physical or sexual injury and did not plausibly allege that the exposure was unrelated to a legitimate governmental objective or excessive in relation to that objective.
3. A § 1983 claim fails when the complaint does not allege each defendant's personal involvement in the asserted constitutional deprivation.
4. A self-represented plaintiff whose complaint is dismissed for failure to state a claim should be permitted an opportunity to amend when the identified deficiencies may be curable.

Questions Presented

1. Whether the complaint stated a plausible Fourteenth Amendment claim based on the alleged forced exposure of detainees' bodies during laundry procedures.
2. Whether the complaint stated a plausible § 1983 claim based on allegedly inadequate blankets, towels, cleaning supplies, and running water when it failed to allege the personal involvement of any defendant.
3. Whether the complaint should be dismissed without prejudice under 28 U.S.C. § 1915A(b)(1) and whether leave to amend should be granted.

Disposition

dismissed