Claude E. Singer v. Slate Belt Medical Center, Northampton County Sheriff's Office, Northampton County Prison, and Sober Health Care Group

Summary

The United States District Court for the Eastern District of Pennsylvania grants Claude E. Singer leave to proceed in forma pauperis and dismisses his complaint under 28 U.S.C. § 1915 for failure to state a claim. The court dismisses with prejudice claims against Slate Belt Medical Center, Saber Healthcare Group, and the Northampton County Sheriff’s Department to the extent described, and dismisses claims against Northampton County Prison as an improper § 1983 defendant. The court permits Singer to amend claims concerning excessive force, deliberate indifference to medical needs, and alleged violations of the Americans with Disabilities Act.

Holdings

1. A complaint filed by a plaintiff proceeding in forma pauperis must be dismissed under 28 U.S.C. § 1915(e)(2)(B)(ii) if it fails to state a claim, applying the Rule 12(b)(6) plausibility standard.
2. A private rehabilitation facility does not become a state actor for purposes of § 1983 merely because it reports suspected conduct to police, answers police questions, receives insurance payments, or may house a person pursuant to a court-related arrangement.
3. A § 1983 claim against a county Sheriff's Office, treated as a claim against the county, requires allegations identifying a county policy or custom that was the proximate cause of the constitutional injury.
4. A plaintiff does not state a false-arrest claim when the arrest was made pursuant to an undisputed, facially valid warrant.
5. The Northampton County Prison is not a person subject to suit under § 1983.
6. The complaint's allegations concerning excessive force during transport and deliberate indifference to medical needs were insufficient as pleaded, but amendment was permitted because the court could not determine that amendment would be futile.
7. A Title II ADA claim requires factual allegations that the plaintiff is a qualified individual with a disability, was denied or excluded from a public entity's services, programs, or activities because of the disability, and that the defendant is a public entity. Money damages additionally require intentional discrimination, including deliberate indifference.

Questions Presented

1. Whether the complaint stated a claim under § 1983 against the private rehabilitation facility and related private entity based on an alleged false report to police and resulting arrest.
2. Whether the claims against the Northampton County Sheriff's Office stated municipal liability under § 1983.
3. Whether the Northampton County Prison was a proper § 1983 defendant.
4. Whether the complaint stated claims for excessive force and deliberate indifference to medical needs under the Fourteenth Amendment.
5. Whether the complaint stated a Title II ADA claim based on denial of medical assessment and mobility devices and whether damages were available.

Disposition

dismissed