James Patrick White v. Warden Payne

Summary

The United States District Court for the Middle District of Florida partially grants and partially denies Defendant Warden Payne’s motion to dismiss James Patrick White’s second amended civil rights complaint. The court allows White’s Eighth Amendment conditions-of-confinement claim concerning the alleged deprivation of hygiene supplies and running water to proceed, while dismissing his Fourteenth Amendment procedural due process claim. Payne is ordered to answer the second amended complaint within twenty-one days.

Holdings

1. White plausibly stated an Eighth Amendment conditions-of-confinement claim by alleging that he was confined for approximately seventy-two hours without basic hygiene supplies and running water, resulting in a fungal infection; the claim could proceed beyond the pleading stage.
2. Payne was not entitled to qualified immunity on White's conditions-of-confinement claim at the motion-to-dismiss stage.
3. White failed to state a Fourteenth Amendment procedural due process claim because his approximately seventy-two-hour placement in strip-cell status did not deprive him of a protected liberty interest requiring notice and a hearing.

Questions Presented

1. Whether White's allegations that he was confined for approximately seventy-two hours without basic hygiene supplies, running water, bedding, or linens stated an Eighth Amendment conditions-of-confinement claim.
2. Whether Payne was entitled to qualified immunity on White's Eighth Amendment conditions-of-confinement claim at the motion-to-dismiss stage.
3. Whether White's placement in strip-cell status without prior notice or a hearing deprived him of a liberty interest protected by the Fourteenth Amendment's Due Process Clause.
4. Whether Payne was entitled to dismissal of White's claims for declaratory and punitive relief at the pleading stage.

Disposition

other