Richard Frank Howell, Jr. v. Nicole Nelson, Quality Correctional Health Services, Dr. Gurley, and Warden Crosby

Summary

The United States District Court for the Middle District of Alabama screened a pro se prisoner’s 42 U.S.C. § 1983 complaint alleging denial of mental-health treatment and prescribed medication. The court found that the complaint did not adequately allege a policy or custom by Quality Correctional Health Services or specific conduct by the individual defendants, and that official-capacity claims for monetary damages were barred. The court granted leave to amend by January 5, 2026, and warned that failure to amend would result in dismissal.

Holdings

1. The complaint failed to state a § 1983 claim against Quality Correctional Health Services because it did not identify a policy or custom of deliberate indifference that caused the alleged denial of medication or mental-health treatment.
2. The complaint failed to state deliberate-indifference claims against Nelson, Dr. Gurley, and Warden Crosby because it did not allege facts showing how each defendant personally participated in or caused the denial of medication or mental-health treatment.
3. Howell’s claims for monetary damages against the individual defendants in their official capacities were subject to dismissal because such claims are treated as claims against the State and are barred by Eleventh Amendment immunity.
4. The court was required to give Howell, a pro se litigant, an opportunity to amend because a more carefully drafted complaint might state a claim.

Questions Presented

1. Whether the complaint adequately stated a § 1983 deliberate-indifference claim against Quality Correctional Health Services without identifying a policy or custom that caused the alleged denial of treatment.
2. Whether the complaint adequately stated § 1983 deliberate-indifference claims against the individual defendants without alleging each defendant’s personal involvement and conduct.
3. Whether official-capacity claims for monetary damages against the individual defendants were barred by Eleventh Amendment immunity.
4. Whether Howell should be given an opportunity to amend his deficient pro se complaint before dismissal.

Disposition

other