Darren Lamont Rice v. Dir. Chadwick Dotson et al.

Summary

The United States District Court for the Western District of Virginia dismissed Darren Lamont Rice’s federal claims arising from alleged inadequate medical treatment, supervisory inaction, disclosure of medical information, and other conduct at Wallens Ridge State Prison. The court granted motions to dismiss filed by Chadwick Dotson, Benny Mullins, and Luciano D’Amato, dismissed additional claims under 28 U.S.C. § 1915A, and declined supplemental jurisdiction over Rice’s state-law claims.

Holdings

1. Rice failed to state official-capacity claims because he did not identify an express policy, final policymaker decision, deliberately indifferent omission, or sufficiently persistent and widespread custom causing his alleged constitutional injuries.
2. Rice failed to state plausible equal-protection, life-and-liberty, or right-to-travel claims.
3. Rice failed to state deliberate-indifference claims against D’Amato and Nauss.
4. Rice failed to state a deliberate-indifference claim against Mullins based on treatment decisions, refusal to provide preferred specialist care, medication decisions, or alleged negligence.
5. Rice’s HIPAA claim failed as a matter of law because HIPAA does not provide a private right of action.
6. Rice failed to state a supervisory-liability claim against Dotson.
7. Rice failed to state plausible constitutional claims against Townsend, Davis, Caughron, Hall, or the Quality Health Office Holder.
8. The court declined to exercise supplemental jurisdiction over Rice’s state-law claims after dismissing all federal claims.

Questions Presented

1. Whether Rice’s second amended complaint stated plausible official-capacity claims under § 1983.
2. Whether Rice adequately pleaded equal-protection, life-and-liberty, and right-to-travel claims.
3. Whether Rice adequately pleaded Eighth Amendment deliberate-indifference claims against the medical and correctional defendants.
4. Whether Rice could bring a private claim under HIPAA for disclosure of medical information.
5. Whether Rice adequately pleaded supervisory liability against Dotson.
6. Whether the court should exercise supplemental jurisdiction over Rice’s state-law claims after dismissing the federal claims.

Disposition

dismissed