Daniel Wayne Roland v. Wayne County Prison, et al.

Summary

The United States District Court for the Middle District of Pennsylvania partially dismisses Daniel Wayne Roland’s amended 42 U.S.C. § 1983 complaint under 28 U.S.C. § 1915(e)(2)(B)(ii). The court dismisses claims against Wayne County Correctional Facility, Acting Sergeant Jaycox, and Correctional Officer Carney, while allowing Eighth Amendment failure-to-protect claims to proceed against Warden Williams, Deputy Warden Masco, and Lieutenant Soccodoto.

Holdings

1. A county prison is not a person subject to suit under Section 1983, and Roland did not allege an unconstitutional policy or custom that could support municipal liability. The claim against Wayne County Correctional Facility was dismissed.
2. Roland plausibly stated Eighth Amendment failure-to-protect claims against Warden Williams, Deputy Warden Masco, and Lieutenant Soccodoto because he alleged a substantial risk of serious harm, their actual awareness of that risk through repeated warnings, and their failure to take action before the assault.
3. Roland failed to plausibly plead deliberate indifference by Officer Carney or Acting Sergeant Jaycox. The allegations against Carney amounted at most to negligence, and the allegation against Jaycox did not establish knowledge of the danger and impermissibly relied on respondeat superior liability.
4. Further leave to amend was denied because Roland had already been given an opportunity to amend and had failed to cure the pleading deficiencies; additional amendment would be futile.

Questions Presented

1. Whether Wayne County Correctional Facility is a person subject to liability under 42 U.S.C. § 1983.
2. Whether Roland plausibly pleaded an Eighth Amendment failure-to-protect claim against Warden Williams, Deputy Warden Masco, and Lieutenant Soccodoto.
3. Whether Roland plausibly pleaded an Eighth Amendment failure-to-protect claim against Acting Sergeant Jaycox and Correctional Officer Carney.
4. Whether further leave to amend should be granted after the deficiencies in the initial complaint and amended complaint.

Disposition

other