Jeffery Hampton v. Vincent Vantiel, Warden, et al.

Summary

The United States District Court for the Middle District of Tennessee grants Jeffery Hampton’s application to proceed in forma pauperis and assesses the statutory filing fee. On initial review under the Prison Litigation Reform Act, the court dismisses the federal claims concerning failure to protect, deliberate indifference to medical needs, and religious exercise for failure to state a claim. Any state-law claims are dismissed without prejudice, and the court certifies that an appeal would not be taken in good faith.

Holdings

1. A prisoner may not recover damages under the Eighth Amendment for fear, mental anguish, or emotional distress arising from allegedly dangerous prison conditions without alleging a compensable physical injury or an actual assault; the complaint therefore failed to state a viable failure-to-protect claim.
2. The complaint failed to state an Eighth Amendment deliberate-indifference claim concerning medical care because the attached records showed that Hampton received medical attention, testing, medication, and ongoing referrals, and his disagreement with the adequacy or timing of treatment did not establish conscious disregard of a serious medical need.
3. The complaint failed to plausibly allege deliberate indifference based on the failure to assign Hampton a bottom bunk because the allegations did not establish that the assigning official knew of the relevant medical need before assigning the available bunks or consciously disregarded Hampton's later grievance.
4. The denial of participation in a single Communion service did not substantially burden Hampton's religious practice and therefore did not state a claim under the First Amendment or RLUIPA.
5. After dismissing all federal claims, the court declined to retain supplemental jurisdiction over the asserted Tennessee-law claims and dismissed those claims without prejudice.

Questions Presented

1. Whether the failure-to-protect and unsafe-conditions allegations stated an Eighth Amendment claim when Hampton alleged fear, mental anguish, and emotional distress but no physical injury or actual assault.
2. Whether the medical-care allegations plausibly established deliberate indifference to a serious medical need under the Eighth Amendment.
3. Whether the denial of a bottom-bunk accommodation plausibly established deliberate indifference to a serious medical need.
4. Whether denial of participation in a single Communion service substantially burdened Hampton's religious exercise under the First Amendment or RLUIPA.
5. Whether the court should retain supplemental jurisdiction over the asserted Tennessee-law claims after dismissing all federal claims.

Disposition

dismissed