Devon Frye v. Nelson Smith, et al.

Summary

The United States District Court for the Eastern District of Virginia considers a motion to dismiss claims brought under 42 U.S.C. § 1983 by civil detainee Devon Frye concerning his double-occupancy housing assignment and alleged risks associated with his night terrors. The court holds that defendants exercised professional judgment under Youngberg v. Romeo and that Frye failed to state a Fourteenth Amendment substantive due process claim. The motion to dismiss is granted as to those claims, while other asserted claims remain pending for further proceedings.

Holdings

1. A civil detainee's substantive liberty interest in safe conditions does not establish a constitutional violation where the challenged housing decision resulted from the exercise of professional judgment and the complaint does not show that the assignment materially increased the detainee's safety risk.
2. Frye could not obtain relief based solely on the alleged harm or risk of harm to his roommate because he lacked standing to litigate another person's rights.
3. The portions of Claims One, Two, Three, Four, Six, and Seven alleging violations of Frye's Fourteenth Amendment substantive due process rights failed to state a claim and were dismissed under Rule 12(b)(6).

Questions Presented

1. Whether Frye stated a Fourteenth Amendment substantive due process claim by alleging that facility officials assigned him a roommate despite his nightmares and night terrors.
2. Whether the documents attached to and incorporated into the complaint established that officials exercised professional judgment in assigning Frye a roommate.
3. Whether Frye could seek relief based on the risk of harm allegedly faced by his roommate.

Disposition

other