Aulton Daniel Goben, III v. Kent County et al.

Summary

The United States District Court for the Western District of Michigan dismisses, at the Prison Litigation Reform Act screening stage, a state prisoner's 42 U.S.C. § 1983 action against Kent County and Kent County Sheriff Michelle LaJoye-Young. The court concludes that the complaint fails to allege a policy or custom causing the constitutional violations and does not establish the named defendants' personal involvement in misconduct attributed to nonparty jail employees.

Holdings

1. The complaint failed to state a municipal-liability claim because it did not identify a policy or custom of Kent County that caused jail employees to act with deliberate indifference to the risk that Plaintiff would be assaulted.
2. The named defendants could not be held liable for alleged constitutional violations committed by nonparty jail employees absent allegations that the named defendants were personally involved in the misconduct or that the misconduct resulted from a qualifying municipal policy or custom.
3. The complaint was subject to dismissal for failure to state a claim under 28 U.S.C. §§ 1915(e)(2) and 1915A(b), and 42 U.S.C. § 1997e(c).

Questions Presented

1. Whether the complaint stated a § 1983 claim against Kent County based on an alleged jail policy allowing upper- and lower-deck inmates to be out of their cells simultaneously during cleanup.
2. Whether Kent County or Sheriff Michelle LaJoye-Young could be held liable for alleged constitutional misconduct committed by jail employees who were not named as defendants.
3. Whether the complaint should be dismissed on preliminary review under the PLRA for failure to state a claim.

Disposition

dismissed