Allison Stacy v. Southwest Virginia Regional Jail Authority, et al.

Summary

The United States District Court for the Western District of Virginia summarily dismisses Allison Stacy’s pro se 42 U.S.C. § 1983 action under 28 U.S.C. § 1915A(b)(1) for failure to state a claim. The court concludes that Stacy failed to allege a qualifying policy or constitutional violation against the Southwest Virginia Regional Jail Authority, identified no actionable conduct by the defendant called “Medical,” and alleged at most negligence by Counselor Trish Sutherland. The dismissal is without prejudice.

Holdings

1. A governmental entity such as a regional jail authority is liable under § 1983 only when its own policy or custom was the moving force behind a constitutional deprivation. Because Stacy did not plausibly allege an underlying constitutional violation resulting from the lockdown policy, she failed to state a claim against the authority.
2. A local jail facility is not a person subject to suit under § 1983 and therefore lacks capacity to be sued as a jail.
3. Allegations that a counselor provided an obituary for the wrong person and that jail personnel failed to provide a requested cellmate did not state a constitutional claim. At most, the obituary allegation suggested negligence, and negligent action by prison officials does not give rise to a constitutional claim; the alleged conduct also fell far short of the unnecessary and wanton infliction of pain required for an Eighth Amendment violation.
4. The complaint failed to state a claim against the defendant identified as Medical because Stacy did not identify any action or inaction by that defendant that allegedly caused her injuries.
5. The complaint failed to state a deliberate-indifference claim under either the Eighth Amendment or the Fourteenth Amendment because Stacy did not allege sufficient facts showing a serious medical condition or injury posing a substantial risk of serious harm, and did not allege facts establishing the defendants' constitutionally culpable knowledge or conduct.

Questions Presented

1. Whether the complaint plausibly stated a § 1983 claim against the Southwest Virginia Regional Jail Authority based on an alleged lockdown policy that allegedly interfered with medical care.
2. Whether the jail facility or the entity identified as Medical could be liable under § 1983 without allegations identifying a suable person or linking an individual defendant's own actions to a constitutional violation.
3. Whether providing an obituary for the wrong person and failing to provide a cellmate during a period of grief stated an Eighth or Fourteenth Amendment claim.
4. Whether the complaint adequately pleaded deliberate indifference to serious medical needs under either the Eighth Amendment or the Fourteenth Amendment.

Disposition

dismissed