Angelo Reynolds v. Bryce Browning, et al.

Summary

The United States District Court for the Southern District of Indiana screened Angelo Reynolds's amended 42 U.S.C. § 1983 complaint concerning an inmate assault, alleged failure to protect, retaliation, and medical care at Wabash Valley Correctional Facility. The court dismissed claims against several defendants, including Centurion Health, and allowed specified First and Eighth Amendment claims to proceed against other defendants. The order also directed service of process and provided a deadline for any motion to reconsider omitted claims.

Holdings

1. A private corporation performing essential services for prisoners may be treated as a municipality for § 1983 purposes, but a plaintiff must identify a policy, practice, custom, or final-decisionmaker action and allege a causal link to the constitutional deprivation. Because Reynolds identified no Centurion policy, practice, or custom that caused his injury, all claims against Centurion were dismissed.
2. Individual liability under § 1983 requires personal involvement and a causal connection between the defendant and the alleged constitutional misconduct. The claims against Sara Bedwell and Sgt. Everado Angeles-Mora were dismissed because the amended complaint did not sufficiently allege that either personally engaged in unconstitutional conduct.
3. Negligence, even gross negligence, is insufficient to support a § 1983 deliberate-indifference claim under the Eighth Amendment. Reynolds's allegations that Nurse Willis performed a poor attempt to stitch his wound alleged at most negligence, and the amended complaint indicated that Dr. Byrd—not Willis—made the final treatment decision; therefore, the claims against Willis were dismissed.
4. The amended complaint plausibly stated claims that could proceed against the identified defendants: First Amendment retaliation against Leffler; Eighth Amendment deliberate indifference to safety against Leffler based on calling Reynolds a snitch and encouraging inmate attacks; Eighth Amendment failure-to-protect claims against Leffler, Vanihel, Allen, and VanVleet; Eighth Amendment deliberate indifference to safety against Browning for failing to intervene in the assault; and Eighth Amendment deliberate indifference to medical needs against Browning, Tomas, and Byrd.

Questions Presented

1. Whether the amended complaint stated a plausible § 1983 claim against Centurion Health without identifying a policy, practice, custom, or final-decisionmaker action causing the alleged constitutional injury.
2. Whether the amended complaint adequately alleged personal involvement by Sara Bedwell and Sgt. Everado Angeles-Mora.
3. Whether allegations that Nurse Makayla Willis performed a poor stitch-up, without more, stated an Eighth Amendment deliberate-indifference claim rather than negligence.
4. Which First and Eighth Amendment claims were sufficiently plausible to proceed past screening.

Disposition

other