Marquan D. Williams v. Albemarle Charlottesville Regional Jail

Summary

The United States District Court for the Western District of Virginia dismissed Marquan D. Williams’s 42 U.S.C. § 1983 action against the Albemarle Charlottesville Regional Jail. The court held that the jail is not a “person” subject to suit under § 1983 and dismissed the action for failure to state a claim under 28 U.S.C. § 1915(e)(2)(B)(ii), after Williams failed to file an amended complaint naming a proper defendant.

Holdings

1. A jail is not a person subject to suit under 42 U.S.C. § 1983.
2. The action must be dismissed for failure to state a claim because the operative complaint names only a non-suable jail as defendant and plaintiff failed to amend after being given an opportunity and warning.
3. The jail is an arm of the Commonwealth of Virginia entitled to Eleventh Amendment immunity.

Questions Presented

1. Whether the Albemarle Charlottesville Regional Jail is a person subject to suit under 42 U.S.C. § 1983.
2. Whether the complaint should be dismissed under 28 U.S.C. § 1915(e)(2)(B)(ii) after the plaintiff failed to amend as ordered.
3. Whether the jail is entitled to Eleventh Amendment immunity as an arm of the Commonwealth of Virginia.

Disposition

dismissed