Joseph Anthony Szostak, III v. Rutherford County Adult Detention Center, et al.

Summary

The United States District Court for the Middle District of Tennessee dismissed Joseph Szostak's pro se 42 U.S.C. § 1983 action against the Rutherford County Adult Detention Center and other defendants. The court held that allegations concerning the plaintiff's inability to eat corn-containing meals did not plausibly establish a substantial risk of serious harm or deprivation of a constitutionally adequate diet under the Fourteenth Amendment. The dismissal was entered under 28 U.S.C. §§ 1915(e)(2)(B)(ii) and 1915A(b)(1) for failure to state a claim.

Holdings

1. The amended complaint failed to state a constitutional claim because Plaintiff did not allege that the food provided was nutritionally or calorically insufficient to maintain normal health, or that the meals caused substantial weight loss, deteriorated health, or another specific physical harm.
2. The action was dismissed under 28 U.S.C. §§ 1915(e)(2)(B)(ii) and 1915A(b)(1) for failure to state a claim upon which relief may be granted.

Questions Presented

1. Whether the amended complaint plausibly alleged that the detention center's failure to provide substitute food for Plaintiff's corn allergy deprived him of a constitutional right under the Fourteenth Amendment.
2. Whether Plaintiff plausibly alleged that the food provided was insufficient to maintain normal health or otherwise posed a substantial risk of serious harm.

Disposition

dismissed