Arion Hollins v. Allen, et al.

Summary

The United States District Court for the Southern District of Indiana screens Arion Hollins's prisoner civil-rights complaint concerning alleged Legionella contamination at Pendleton Correctional Facility and alleged failures to test or treat him. The court dismisses claims against Governor Mike Braun, former IDOC Commissioner Robert E. Carter, Dr. John Nwannunu, and the IDOC Director of Classification for lack of personal involvement. Eighth Amendment claims proceed against Warden Allen, Kristin Partain, and Nurse Practitioner Abby, and the court directs service of process.

Holdings

1. A § 1983 claim requires the plaintiff to allege the defendant's personal involvement in the asserted constitutional deprivation and a causal connection between the defendant and the alleged misconduct; claims lacking such allegations were dismissed.
2. States and their agencies are not persons subject to suit under 42 U.S.C. § 1983.
3. The complaint stated an Eighth Amendment conditions-of-confinement claim sufficient to proceed against Warden Allen.
4. The complaint stated Eighth Amendment deliberate-indifference claims sufficient to proceed against Nurse Partain and Nurse Practitioner Abby.
5. Under 28 U.S.C. § 1915A, claims that are frivolous, malicious, fail to state a claim, or seek relief from an immune defendant must be dismissed; applying the Rule 12(b)(6) plausibility standard, the court dismissed nonviable claims and allowed the identified viable claims to proceed.

Questions Presented

1. Whether the complaint stated claims under 42 U.S.C. § 1983 against the named defendants under the Prison Litigation Reform Act screening standard.
2. Whether the complaint alleged sufficient personal involvement by Governor Mike Braun, former IDOC Commissioner Robert E. Carter, Jr., Dr. John Nwannunu, and the John Doe IDOC Director of Classification.
3. Whether the allegations stated an Eighth Amendment conditions-of-confinement claim against Warden Allen and Eighth Amendment deliberate-indifference claims against Nurses Partain and Abby.

Disposition

other