Summary
The court screened a pro se prisoner’s amended 42 U.S.C. § 1983 complaint alleging deliberate indifference to serious medical needs at the Elmore County Jail. It dismissed the claims against Quality Correctional Health Care, Warden Tracy Jackson, Nurse Terry, and Nurse Meghan without prejudice, while allowing the claims against Nurse Zack to proceed and ordering service.
Holdings
- The amended complaint failed to state plausible § 1983 deliberate-indifference claims against Quality Correctional Health Care, Warden Tracy Jackson, Nurse Terry, and Nurse Meghan because it did not allege the specific acts or omissions of each defendant that caused the inadequate medical care.
- The amended complaint stated a sufficient § 1983 Eighth Amendment deliberate-indifference claim against Nurse Zack to proceed beyond screening.
- The court permitted the amended complaint because leave to amend should be freely given when justice so requires.
Questions Presented
- Whether the amended complaint stated a plausible 42 U.S.C. § 1983 Eighth Amendment deliberate-indifference claim against Quality Correctional Health Care, Warden Tracy Jackson, Nurse Terry, and Nurse Meghan.
- Whether the amended complaint stated a plausible deliberate-indifference claim against Nurse Zack sufficient to proceed past statutory screening.
- Whether the amended complaint could be accepted despite Mack’s failure to seek leave of court before amending the complaint.
Disposition
other
Cases Cited (13)
- Douglas v. Yates, 535 F.3d 1316, 1320, 1321-22 (11th Cir. 2008)(followed)
- Ashcroft v. Iqbal, 556 U.S. 662, 678 (2009)(followed)
- Bell Atl. Corp. v. Twombly, 550 U.S. 544, 555, 557, 570 (2007)(followed)
- Hutchinson v. Wexford Health Servs., Inc., 638 F. App’x 930, 932 (11th Cir. 2016) (per curiam)(followed)
- Bilal v. Geo Care, LLC, 981 F.3d 903, 911 (11th Cir. 2020)(followed)
- Erickson v. Pardus, 551 U.S. 89, 94 (2007)(followed)
- GJR Invs. v. Escambia Cnty., 132 F.3d 1359, 1369 (11th Cir. 1998), overruled on other grounds by Ashcroft v. Iqbal, 556 U.S. 662 (2009)(limited)
- Wade v. McDade, 106 F.4th 1251, 1255, 1262 (11th Cir. 2024) (en banc)(followed)
- Wingo v. WellStar Health Sys., Inc., ___ F.4th ___, 2025 WL 3442596, at *4 (11th Cir. Dec. 1, 2025)(followed)
- Goebert v. Lee County, 510 F.3d 1312, 1326 (11th Cir. 2007)(followed)
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Cited In (0)
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Court Document
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