Michael Keith Mitchell v. f/n/u l/n/u Assistant Commissioner of Prisons, et al.

Summary

The United States District Court for the Middle District of Tennessee screened Michael Keith Mitchell’s pro se 42 U.S.C. § 1983 complaint under the Prison Litigation Reform Act. The court concluded that the complaint failed to state claims against the assistant commissioner, warden, and healthcare supervisor in their individual or official capacities, and dismissed the action. The court also denied in forma pauperis status for any appeal.

Holdings

1. A prison official's failure to take corrective action in response to an inmate grievance, without allegations of direct participation, authorization, approval, or knowing acquiescence in the underlying misconduct, does not establish personal involvement or supervisory liability under § 1983.
2. Official-capacity claims for money damages against the Warden and Assistant Commissioner are claims against the Tennessee Department of Correction and are barred by Eleventh Amendment sovereign immunity.
3. The official-capacity claims for injunctive relief fail because the complaint did not identify a TDOC or Tennessee policy or custom that directly caused the alleged constitutional violation.
4. The complaint failed to state an Eighth Amendment deliberate-indifference claim against Solomon because, even assuming the rapid weight loss was a sufficiently serious medical need, the allegations did not show that Solomon subjectively disregarded a substantial risk of harm.
5. The complaint failed to state a § 1983 claim against Corizon/Centurion because it did not identify a corporate policy or custom that was the moving force behind the alleged injury.

Questions Presented

1. Whether the claims against the Assistant Commissioner of Prisons and the Warden based on their handling of grievances stated a § 1983 claim through personal involvement or supervisory liability.
2. Whether official-capacity claims for damages against the Warden and Assistant Commissioner were barred by sovereign immunity.
3. Whether the official-capacity claims for injunctive relief against the Warden and Assistant Commissioner adequately alleged that a state policy or custom caused the constitutional injury.
4. Whether the individual-capacity claim against Solomon adequately alleged deliberate indifference to a serious medical need under the Eighth Amendment.
5. Whether the official-capacity claim against Solomon adequately alleged that a policy or custom of Corizon/Centurion caused the alleged constitutional violation.

Disposition

dismissed