David Galeski v. Heidi Washington et al.

Summary

The United States District Court for the Western District of Michigan conducts preliminary screening under the Prison Litigation Reform Act of a state prisoner’s § 1983 and Americans with Disabilities Act claims concerning housing, failure to protect, and accommodations for gender dysphoria. The court dismisses claims against Heidi Washington and Brian Hadden, official-capacity damages claims, individual-capacity ADA claims, and redundant ADA claims, while allowing Eighth Amendment failure-to-protect and official-capacity ADA accommodation claims against Craig Ritter and Unknown Chevette to proceed. The court also denies the plaintiff’s motion for a temporary restraining order and preliminary injunction.

Holdings

1. The complaint plausibly stated Eighth Amendment failure-to-protect claims against Ritter and Chevette in their individual capacities and in their official capacities for injunctive and declaratory relief.
2. The plaintiff's official-capacity claims for monetary damages under § 1983 were dismissed because the claims were effectively against the MDOC, which is immune from such suits and is not a person subject to liability for damages under § 1983.
3. The individual-capacity § 1983 claims against Washington and Hadden were dismissed for failure to state a claim.
4. The individual-capacity ADA claims were dismissed because Title II does not impose liability on individual government officials.
5. The plaintiff was allowed to proceed on official-capacity ADA failure-to-accommodate claims against Ritter and Chevette, while the official-capacity ADA claims against Washington and Hadden were dismissed as redundant.
6. The motion for a temporary restraining order and preliminary injunction was denied without prejudice.

Questions Presented

1. Whether the complaint stated an Eighth Amendment failure-to-protect claim against Ritter and Chevette.
2. Whether the complaint stated individual-capacity claims under Title II of the ADA.
3. Whether official-capacity claims for monetary damages under § 1983 were barred by Eleventh Amendment immunity and the absence of a statutory person.
4. Whether the complaint stated claims against Washington and Hadden based on supervisory liability, grievance handling, policies, or alleged failures to train and supervise.
5. Whether the complaint stated official-capacity ADA failure-to-accommodate claims against Ritter and Chevette.
6. Whether the plaintiff was entitled to a temporary restraining order or preliminary injunction.

Disposition

other