Jaycob Hendren v. Frank Strada, et al.

Summary

The United States District Court for the Eastern District of Tennessee grants Jaycob Hendren leave to proceed in forma pauperis and assesses the $350 civil filing fee under the Prison Litigation Reform Act. The court dismisses the complaint under the screening provisions of the PLRA for failure to state plausible claims concerning recreation restrictions, visual cavity searches, and failure to train or supervise. The court permits Hendren fourteen days to file an amended complaint limited to claims arising from the original complaint.

Holdings

1. Plaintiff failed to state a plausible Eighth Amendment claim because he did not identify the responsible policymaker, did not describe the extent of the deprivation or allege that he could not exercise in his cell, did not allege that his mental-health conditions worsened, and the temporary lockdown was supported by a legitimate penological justification.
2. Plaintiff failed to state a plausible Fourth Amendment claim because the searches occurred in the context of a security lockdown following an officer's murder, were allegedly conducted in the cell with guards and a cellmate present, and were supported by apparent legitimate penological justifications.
3. Alleged failure to follow Tennessee Department of Correction policies, including PREA policies, did not independently establish a constitutional violation under § 1983.
4. Plaintiff could not assert constitutional claims based solely on the alleged treatment of other prisoners because a prisoner proceeding in an individual-capacity conditions-of-confinement action generally may assert only violations of his own constitutional rights.
5. Plaintiff failed to state a failure-to-train or failure-to-supervise claim because he did not identify an underlying constitutional injury; the searches he challenged were not plausibly unreasonable.

Questions Presented

1. Whether Plaintiff plausibly alleged that the temporary denial of recreation during a prison lockdown violated the Eighth Amendment.
2. Whether the alleged strip and visual body-cavity searches before showers, including possible observation by officers of the opposite sex, plausibly violated the Fourth Amendment.
3. Whether alleged failure to follow Tennessee Department of Correction PREA policies stated a constitutional claim under 42 U.S.C. § 1983.
4. Whether Plaintiff stated a claim for failure to train or supervise prison staff when the underlying searches were not plausibly unconstitutional.
5. Whether Plaintiff should be permitted to amend the complaint after dismissal at the PLRA screening stage.

Disposition

dismissed