Larry Allen Young, Jr. v. Chadwick Dotson, et al.

Summary

The United States District Court for the Western District of Virginia granted the defendants’ Rule 12(b)(6) motion to dismiss Larry Allen Young, Jr.’s 42 U.S.C. § 1983 claim. Young alleged that prison officials violated the Eighth Amendment by placing him in a double cell despite his prior single-cell housing, history of sexual assault, and reported mental health issues. The court held that the complaint did not allege a specific known risk of harm, deliberate indifference to a serious mental health need, resulting injury, or a constitutional violation based solely on alleged violations of prison policy.

Holdings

1. Young failed to state an Eighth Amendment failure-to-protect claim because he did not allege a specific known risk of serious harm posed by the cellmate or that any defendant actually knew of and disregarded such a risk.
2. Young failed to state a claim for deliberate indifference to a serious mental-health need because he did not allege a sufficiently serious mental-health need requiring particular treatment, a denied request for treatment, or defendants' knowledge of and disregard for an excessive risk.
3. Alleged failure to follow VDOC classification, orientation, or housing policies, standing alone, does not constitute a violation of the Constitution actionable under § 1983.
4. Section 1983 liability must be based on each defendant's own constitutional violation; respondeat superior does not apply.

Questions Presented

1. Whether Young plausibly alleged an Eighth Amendment failure-to-protect claim based on being housed with a cellmate.
2. Whether Young plausibly alleged deliberate indifference to a serious mental-health need based on his housing assignment.
3. Whether alleged violations of VDOC classification, orientation, or housing policies state a constitutional claim under 42 U.S.C. § 1983.

Disposition

dismissed