Darrell Jesse Rivera v. Mediko Correctional Healthcare, et al.

Summary

The United States District Court for the Middle District of Pennsylvania screened Darrell Jesse Rivera’s pro se 42 U.S.C. § 1983 complaint concerning the alleged denial of a medically necessary mattress at Dauphin County Prison. The court granted in forma pauperis status, dismissed claims against Dauphin County Prison with prejudice, and dismissed claims against Mediko Correctional Healthcare and its medical staff without prejudice for failure to allege personal involvement or a qualifying policy or custom. The court granted leave to file an amended complaint.

Holdings

1. Dauphin County Prison is not a person within the meaning of § 1983 and therefore cannot be sued under that statute; the claims against it were dismissed with prejudice.
2. The complaint failed to state a § 1983 claim against Mediko Correctional Healthcare because it did not allege that a Mediko policy, custom, or practice caused the asserted constitutional violation. The claims against Mediko were dismissed without prejudice.
3. The complaint failed to state claims against Mediko's entire medical staff because it did not identify specific actions by any individual staff member or allege each individual's personal involvement. Those claims were dismissed without prejudice.
4. Rivera was entitled to leave to file an amended complaint to cure the pleading defects.

Questions Presented

1. Whether the complaint stated a viable 42 U.S.C. § 1983 claim against Dauphin County Prison.
2. Whether the complaint stated a viable § 1983 claim against Mediko Correctional Healthcare based on the alleged failure to respond to Rivera's medical request.
3. Whether the complaint stated a viable § 1983 claim against the entire medical staff of Mediko Correctional Healthcare without identifying specific acts or individual participation.
4. Whether Rivera should be granted leave to amend the deficient complaint.

Disposition

other