Charles Wallis, Christopher B. Goins, and Mark Wells v. Jefferson County Jail Staff, J. Coffey, and Amber Manning

Summary

The United States District Court for the Eastern District of Tennessee considers a pro se 42 U.S.C. § 1983 complaint challenging 23-hour-per-day lockdown conditions at the Jefferson County Jail. The court dismisses the two additional plaintiffs who did not sign the complaint, grants Charles Wallis leave to proceed in forma pauperis, and dismisses the action without prejudice for failure to state a claim. The court concludes that 23-hour lockdown confinement, as alleged, does not constitute an atypical and significant hardship or an extreme deprivation of basic necessities.

Holdings

1. Goins and Wells could not proceed as plaintiffs because they did not sign the complaint or otherwise demonstrate that they were actively pursuing the action; the court therefore dismissed them from the case.
2. The complaint failed to state a plausible claim under § 1983 because confinement to a cell for 23 hours per day, without additional facts showing an extreme deprivation or atypical and significant hardship, did not establish a constitutional violation.
3. The court declined to permit amendment because the complaint's substantive allegations failed to state a plausible claim even apart from its failure to include a demand for relief.
4. Wallis was granted leave to proceed in forma pauperis, but he remained responsible for the $350 civil filing fee, payable through the statutory inmate-account collection procedure.

Questions Presented

1. Whether prisoners who did not sign the complaint or seek in forma pauperis status could proceed as plaintiffs in the same action.
2. Whether the complaint stated a plausible constitutional claim under 42 U.S.C. § 1983 based on confinement in a 23-hours-per-day lockdown and resulting depression-medication use.
3. Whether Wallis should be permitted to amend the complaint to supply a demand for relief.

Disposition

dismissed