Tyler Franklin, Individually, and as Administrator of the Estate of John Hunter Franklin v. Corporal Garrett Williamson, Corporal Jason Workman, Training Officer Fred Ferguson, and Correctional Officer Samuel Adkins

Summary

The United States District Court for the Southern District of West Virginia grants the motions to dismiss filed by Corporal Jason Workman, Corporal Garrett Williamson, and Correctional Officer Samuel Adkins, and denies as moot a joint motion to stay discovery. The court addresses relation back under Federal Rule of Civil Procedure 15(c), concluding that the claims against Williamson and Adkins do not relate back because of prejudice, while rejecting Workman’s statute-of-limitations argument. The court also analyzes qualified immunity and deliberate indifference claims arising from the suicide of an incarcerated individual.

Holdings

1. The court could extend the Rule 4(m) service period for good cause, and the extension made service on Williamson and Adkins timely for purposes of Rule 15(c)(1)(C).
2. The claims against Williamson and Adkins did not relate back because Plaintiff failed to show that they would not be prejudiced in defending the action on the merits.
3. The claims against Workman were not dismissed as untimely because the court's Rule 4(m) extension made his notice timely and Workman did not argue that he would be prejudiced in defending on the merits.
4. Workman was entitled to qualified immunity because the alleged facts did not establish deliberate indifference in violation of the Eighth Amendment.

Questions Presented

1. Whether the claims against Williamson and Adkins, added after the limitations period, related back to the original complaint under Federal Rule of Civil Procedure 15(c)(1)(C).
2. Whether the court's extension of the Rule 4(m) service period made service on Williamson and Adkins timely.
3. Whether the claims against Williamson and Adkins failed to satisfy Rule 15(c)(1)(C)(i) because they would be prejudiced in defending the action.
4. Whether the claims against Workman were barred by the statute of limitations because they did not relate back under Rule 15(c)(1)(C).
5. Whether Workman was entitled to qualified immunity because the alleged conduct did not constitute deliberate indifference to a serious medical or safety need.

Disposition

dismissed