Connie Arnold v. Centurion of Tennessee, LLC, et al.

Summary

The United States District Court for the Eastern District of Tennessee dismissed Connie Arnold’s pro se 42 U.S.C. § 1983 action against Centurion of Tennessee and several correctional and medical defendants. The court held that most claims were barred by Tennessee’s one-year statute of limitations and that the continuing-violation doctrine did not apply. The remaining claims, including claims under the ADA, Rehabilitation Act, Title VII, and allegations concerning later medical-care incidents, were dismissed for failure to state a claim.

Holdings

1. Arnold's § 1983 claims based on incidents occurring before August 15, 2023, were barred by Tennessee's one-year statute of limitations.
2. The continuing-violation doctrine did not save Arnold's untimely claims because the alleged events were discrete, separately actionable incidents rather than continuing unlawful acts.
3. Arnold failed to state an ADA or Rehabilitation Act claim because the statutes do not impose liability on individual defendants or the private entity Centurion under the allegations presented, and he pleaded no facts plausibly showing disability discrimination.
4. Arnold failed to state a Title VII claim because his amended complaint did not plausibly allege the elements of employment discrimination or harassment.
5. Arnold failed to state a § 1983 deliberate-indifference claim based on the alleged denial of medication and an eye-specialist appointment on August 15, 2023.
6. Arnold failed to state an Eighth Amendment deliberate-indifference claim based on the August 29, 2023, treatment of his left-hand pain.

Questions Presented

1. Whether Arnold's claims arising from incidents before August 15, 2023, were barred by Tennessee's one-year statute of limitations.
2. Whether the continuing-violation doctrine saved Arnold's otherwise untimely § 1983 claims.
3. Whether Arnold stated viable claims under the ADA and Rehabilitation Act against the named defendants.
4. Whether Arnold stated a Title VII claim.
5. Whether the August 15, 2023, denial of requests for medication and an eye specialist stated a § 1983 deliberate-indifference claim.
6. Whether the August 29, 2023, allegations concerning left-hand pain stated an Eighth Amendment deliberate-indifference claim.

Disposition

dismissed