Gary Montgomery v. Aramark of Tennessee, LLC, Shawn Phillips, Stacey Oaks, Frank Strada, Officer Duncan, and John Doe

Summary

The United States District Court for the Eastern District of Tennessee granted Gary Montgomery leave to proceed in forma pauperis and leave to amend his prisoner civil-rights complaint. The court dismissed his claims under 42 U.S.C. §§ 1983 and 1985 for failure to state a claim, finding insufficient allegations of harm, personal involvement, supervisory liability, or conspiracy. The court declined supplemental jurisdiction over the Tennessee-law claims and dismissed them without prejudice.

Holdings

1. A prisoner does not state a plausible Eighth Amendment claim based on temporary denial of a prescribed diabetic diet without alleging that the deprivation caused a negative health consequence or other particular injury.
2. Official-capacity claims against TDOC employees are claims against the State of Tennessee and must be dismissed because a State is not a person subject to suit under 42 U.S.C. § 1983.
3. A § 1983 claim cannot rest solely on a defendant's supervisory position; the plaintiff must allege each defendant's personal involvement or direct participation in the constitutional violation.
4. A private entity providing prison services may be liable under § 1983 only upon a plausible allegation that a policy or custom caused a particular constitutional injury; Montgomery alleged neither a particular injury nor a sufficient causal constitutional violation.
5. A § 1985 claim fails when the complaint alleges no facts supporting the existence of a conspiracy or an actionable deprivation within the statute.
6. When all federal claims are dismissed before trial, the court may decline supplemental jurisdiction over remaining state-law claims and dismiss them without prejudice.

Questions Presented

1. Whether the amended complaint plausibly alleged an Eighth Amendment claim under 42 U.S.C. § 1983 based on temporary denial of diabetic meals and a single missed meal.
2. Whether the official-capacity claims against TDOC employees were barred because the claims were effectively against the State of Tennessee.
3. Whether the complaint plausibly alleged individual or supervisory liability against the TDOC defendants and Officer Duncan.
4. Whether the complaint plausibly alleged that an Aramark policy or custom caused a constitutional injury.
5. Whether the complaint stated a claim under 42 U.S.C. § 1985.
6. Whether the court should exercise supplemental jurisdiction over the Tennessee-law claims after dismissing the federal claims.

Disposition

dismissed