Kenneth Allen Washington v. Calvaral, Vangody

Summary

The United States District Court for the Northern District of Indiana screened Kenneth Allen Washington’s amended prisoner complaint under 28 U.S.C. § 1915A. The court found that the complaint did not plausibly state claims concerning medical care or excessive force, but granted leave to file a second amended complaint clarifying the dates, locations, factual allegations, and alleged injuries. The court also denied motions for a docket sheet and cautioned that false statements under penalty of perjury could result in sanctions.

Holdings

1. The amended complaint did not state a plausible inadequate-medical-care claim because the alleged stomach pain, two episodes of vomiting, weakness, fatigue, and generalized illness did not establish an objectively serious medical need, and the allegations did not show constitutionally unreasonable treatment.
2. The amended complaint did not state a plausible Fourteenth Amendment excessive-force claim because it did not adequately describe the circumstances leading to the force, the force used, Washington's response, the resulting injuries, or the subsequent medical care.
3. Washington was granted leave to file a second amended complaint because the deficiencies might be curable through clarification and amendment at the early pleading stage.

Questions Presented

1. Whether the amended complaint plausibly alleged a Fourteenth Amendment claim for constitutionally inadequate medical care.
2. Whether the amended complaint plausibly alleged a Fourteenth Amendment excessive-force claim against the deputies.
3. Whether Washington should be granted leave to file a second amended complaint to clarify the dates, locations, factual allegations, and identities of the persons involved.
4. Whether Washington's motions for a docket sheet should be denied as unnecessary.

Disposition

other