Jeremy Cordero Crawley v. Rick White, et al.

Summary

The United States District Court for the Western District of Virginia dismissed Jeremy Cordero Crawley’s 42 U.S.C. § 1983 action without prejudice under 28 U.S.C. § 1915A(b)(1). The court held that allegations concerning inadequate cell cleaning and the denial of cleaning supplies did not plausibly establish an objectively sufficiently serious Eighth Amendment conditions-of-confinement violation. The court also found that Crawley’s allegations of exposure to infectious disease, COVID-19 risk, emotional distress, and mental anguish were insufficiently specific or serious.

Holdings

1. The complaint failed to state an Eighth Amendment conditions-of-confinement claim because Crawley did not allege facts showing that the condition of his cell was sufficiently extreme, that he suffered a serious or significant physical or emotional injury, or that he faced a substantial risk of serious harm.
2. The court dismissed the action without prejudice because the complaint failed to state a claim upon which relief could be granted.

Questions Presented

1. Whether Crawley's allegations that prison officials failed to clean his cell and provide cleaning materials plausibly stated an Eighth Amendment conditions-of-confinement claim.
2. Whether the complaint should be dismissed under 28 U.S.C. § 1915A(b)(1) for failure to state a claim.

Disposition

dismissed