Devin L. Brown v. Helene L. White, Matthew D. Kotkosky, Reece R. Volp, Kevin R. Jennerjohn, Marcelo A. Garcia, Cesar A. Caro, and Brandon Veltus

Summary

The United States District Court for the Eastern District of Wisconsin screened Devin L. Brown’s 42 U.S.C. § 1983 complaint alleging that correctional officers were deliberately indifferent to his serious medical condition after he collapsed from a heart attack. The court granted Brown in forma pauperis status but dismissed the federal claims for failure to state an Eighth Amendment claim, concluding that the defendants responded reasonably and that any failure to provide additional care amounted at most to negligence. The court dismissed purported state-law claims without prejudice for lack of jurisdiction and denied leave to amend as futile.

Holdings

1. Brown failed to state an Eighth Amendment claim because the alleged facts showed that the correctional officers responded to the emergency by securing the area, summoning assistance, and assisting Brown, rather than ignoring or minimizing his condition. Their failure to provide Brown's preferred or perfect treatment amounted at most to negligence, not deliberate indifference.
2. After Brown failed to state a federal claim, the court lacked jurisdiction over his purported state-law claims and dismissed those claims without prejudice.
3. Leave to amend was denied because amendment would be futile.

Questions Presented

1. Whether Brown's allegations plausibly stated an Eighth Amendment deliberate-indifference claim against the correctional officers based on their response to his medical emergency.
2. Whether the court had jurisdiction over Brown's purported state-law claims after dismissing the federal claim.
3. Whether Brown should be granted leave to amend his complaint.

Disposition

dismissed