Summary
The court dismissed Jesse Ryan Stiltner’s pro se 42 U.S.C. § 1983 complaint without prejudice for failure to state a claim. The court held that the complaint did not allege a policy or custom sufficient to impose liability on Wexford and that HIPAA does not create a private right of action under § 1983; alleged laughter and verbal harassment also did not state a constitutional claim.
Court
United States District Court for the Western District of Virginia, Roanoke Division
Jurisdiction
United States District Court for the Western District of Virginia, Roanoke Division
Decision date
June 12, 2026
Docket number
7:25CV00602
Disposition
dismissed
Questions Presented
- Whether the complaint stated a plausible § 1983 claim against Wexford Health Service based on an alleged deprivation of adequate medical care.
- Whether HIPAA creates a private right of action enforceable through 42 U.S.C. § 1983.
- Whether an officer's presence during a medical appointment, alleged listening to personal medical information, and laughter or verbal harassment stated a constitutional claim under § 1983.
Holdings
- The complaint failed to state a plausible § 1983 claim against Wexford because it alleged no official policy or custom of the corporation that caused a deprivation of federal rights.
- HIPAA does not create a private right to sue that may be enforced through § 1983; therefore, Stiltner could not state a § 1983 claim based solely on the alleged HIPAA violation.
- The alleged conduct by Officer Rosa did not state a plausible constitutional claim under § 1983 because laughing or other verbal harassment by prison officials, without more, is constitutionally insufficient.
Court Document
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