Keywuan Melvin v. C/O Carlisle, C/O Johnson, C/O Stover, Lt. Clark, Sgt. Bridwell, Marsh, Robinson, Sgt. Hollis, C/O Stark, C/O Narsh, C/O Cooper, C/O Emmas, and Dr. Bell

Summary

The United States District Court for the Southern District of Illinois conducted preliminary screening under 28 U.S.C. § 1915A of Keywuan Melvin’s 42 U.S.C. § 1983 complaint concerning alleged deliberate indifference to his medical needs after he swallowed rusty nail clippers. The court allowed the Eighth Amendment deliberate-indifference medical claim to proceed against the named defendants, while dismissing claims concerning premature removal from crisis watch and sexual comments during a search.

Holdings

1. The complaint stated a colorable deliberate-indifference claim against Carlisle, Johnson, Stover, Clark, Bridwell, Marsh, Robinson, Hollis, Stark, Narsh, Cooper, Emmas, and Bell because Melvin alleged an objectively serious medical condition and that each defendant knew of the risk yet failed to obtain medical assistance.
2. Count 2 was dismissed for failure to state a claim because the allegation that Robinson removed Melvin from crisis watch without researching his condition described, at most, negligence or malpractice rather than deliberate indifference.
3. Count 3 was dismissed because Stover's alleged single instance of sexual comments during a strip search and metal-detector examination, without allegations that other prisoners overheard the comments, that Melvin was placed at risk of assault, or that he suffered mental distress, did not rise to an Eighth Amendment violation.
4. Claims against a John Doe correctional officer and Jane Doe nurses not named in the complaint's caption were dismissed without prejudice because individuals not identified as defendants in the caption are not treated as parties.

Questions Presented

1. Whether Melvin stated an Eighth Amendment deliberate-indifference claim against the named defendants based on their alleged failure to obtain emergency medical treatment after he swallowed rusty nail clippers.
2. Whether Melvin stated an Eighth Amendment deliberate-indifference claim against Robinson based on her alleged premature removal of him from crisis watch.
3. Whether Stover's alleged sexual comments during a strip search and metal-detector examination stated an Eighth Amendment cruel-and-unusual-punishment claim.
4. Whether claims against individuals not named in the complaint's caption and allegations of state-law official misconduct could proceed in the § 1983 action.

Disposition

other