Waheed Jenkins v. Department of Corrections, et al.

Summary

The United States District Court for the Middle District of Pennsylvania dismissed Waheed Jenkins's pro se 42 U.S.C. § 1983 complaint under 28 U.S.C. § 1915A(b)(1) for failure to state a claim. The court held that Jenkins failed to adequately plead personal involvement, deliberate indifference to serious medical needs, a protected liberty interest supporting procedural due process, or a constitutional violation by a corrections officer, and that claims against the Department of Corrections and official-capacity damages claims were barred. The court granted limited leave to amend, while dismissing several claims with prejudice.

Holdings

1. A § 1983 plaintiff must plead each defendant's personal involvement in the alleged constitutional misconduct; respondeat superior and conclusory allegations of supervisory responsibility are insufficient.
2. The Pennsylvania Department of Corrections is not a person subject to suit under 42 U.S.C. § 1983, and Jenkins's damages claim against it was properly dismissed with prejudice.
3. Jenkins failed to state an Eighth Amendment deliberate-indifference claim against Nurse Hall because alleging negligent medical judgment, without deliberate indifference and resulting harm, does not establish a constitutional violation.
4. Official-capacity claims for monetary damages against Pennsylvania state officials are barred by Eleventh Amendment sovereign immunity.
5. Jenkins failed to state a procedural due process claim based on 15 days in the RHU because he did not identify a protected liberty interest; the claim was dismissed with prejudice.
6. Jenkins failed to state a § 1983 claim against Shearn because informing a visitor that Jenkins was in disciplinary custody for drugs, without identifying a constitutional or federal-law right violated, was insufficient; the claim was dismissed with prejudice.

Questions Presented

1. Whether Jenkins plausibly alleged personal involvement by Superintendent McGinley in a constitutional violation.
2. Whether the Pennsylvania Department of Corrections is a person subject to liability under 42 U.S.C. § 1983.
3. Whether Jenkins plausibly alleged deliberate indifference to serious medical needs under the Eighth Amendment against Nurse Hall.
4. Whether official-capacity claims for monetary damages are barred by Eleventh Amendment sovereign immunity.
5. Whether Jenkins alleged a protected liberty interest sufficient to support a Fourteenth Amendment procedural due process claim based on 15 days in the RHU.
6. Whether Jenkins stated a § 1983 claim based on Corrections Officer Shearn's statement to a visitor.

Disposition

dismissed