Alvin John Langsford, III v. Judge Jerry Edwards, Jr., Morehouse Parish Jail, et al.

Summary

This Report and Recommendation addresses a pro se prisoner’s 42 U.S.C. § 1983 claims arising from alleged excessive force, failure to protect, denial or delay of medical care, unsafe confinement, retaliation, and related conditions at Morehouse Parish Jail. The magistrate judge recommends retaining claims against Lieutenant Don Taylor and Warden Trevor Wilhite concerning excessive force, failure to protect, and certain medical-care allegations, while dismissing other claims and requests for criminal prosecution or employment discipline.

Holdings

1. Langsford plausibly stated an Eighth Amendment excessive-force claim against Lieutenant Taylor because the alleged choking, attempted leg break, and shooting with a mace-ball rifle caused more-than-de-minimis injuries and, as pleaded, were not applied in a good-faith effort to maintain or restore discipline.
2. Langsford plausibly stated an Eighth Amendment failure-to-protect claim against Warden Wilhite.
3. Langsford plausibly stated deliberate-indifference claims against Taylor and Wilhite for failing to provide or arrange mace decontamination and wound care after the shooting.
4. Langsford plausibly stated a deliberate-indifference claim against Taylor for disregarding requests for follow-up wound care after Langsford returned from the hospital.
5. The allegation that Morehouse Parish Jail lacked on-site medical staff during the night shift did not, standing alone, state a plausible constitutional violation.
6. Langsford was not entitled to an order directing criminal prosecution or the firing or demotion of defendants.
7. Morehouse Parish Jail was not a juridical person capable of being sued under Louisiana law.
8. Langsford's claims against Sheriff Tubbs and, except for the specifically retained claim, Warden Wilhite failed because they were based on supervisory status and vicarious liability rather than personal involvement or a causally connected unconstitutional policy.

Questions Presented

1. Whether Langsford plausibly stated an Eighth Amendment excessive-force claim against Lieutenant Taylor.
2. Whether Langsford plausibly stated an Eighth Amendment failure-to-protect claim against Warden Wilhite concerning Taylor's use of the mace-ball rifle.
3. Whether Langsford plausibly stated deliberate-indifference claims against Taylor and Wilhite for failure to provide mace decontamination and wound care.
4. Whether Langsford plausibly stated a deliberate-indifference claim against Taylor for delaying follow-up wound care after Langsford's hospital visit.
5. Whether the allegation that Morehouse Parish Jail lacked on-site medical staff during the night shift stated a constitutional claim.
6. Whether vague, group-pleading allegations against defendants, supervisory-liability allegations, and claims concerning unidentified actors stated claims under § 1983.
7. Whether Langsford could obtain monetary compensation for mental or emotional injuries under 42 U.S.C. § 1997e(e) without a related physical injury.
8. Whether the court could order criminal prosecution, firing, or demotion of the defendants.
9. Whether Morehouse Parish Jail was an entity capable of being sued under Louisiana law.

Disposition

other