Robert Kenneth Hill v. Duffield Regional Jail

Hill · United States District Court for the Western District of Virginia, Roanoke Division · June 4, 2026 · No. 7:26-cv-00222

Summary

The court dismissed Robert Kenneth Hill’s 42 U.S.C. § 1983 action at the screening stage under 28 U.S.C. § 1915A. It held that Duffield Regional Jail was not a suable entity and that seeking credit toward a sentence through a § 1983 action was improper because such relief must be pursued through habeas corpus.

Holdings

  1. Duffield Regional Jail is not a suable entity under § 1983, so the complaint fails to state a claim against it.
  2. A § 1983 action is not the proper vehicle for a claim seeking to shorten the length of a sentence; such a challenge must be brought through habeas corpus.

Questions Presented

  1. Whether Duffield Regional Jail is a suable entity under 42 U.S.C. § 1983.
  2. Whether a § 1983 action is an appropriate vehicle for a claim seeking credit that would shorten the plaintiff's sentence.

Disposition

dismissed

Cases Cited (4)

  • Napier v. Ohai, Case No. 7:23-cv-00098, 2025 WL 2779900, at *3 (W.D. Va. Sept. 26, 2025)(followed)
  • Wilkinson v. Dotson, 544 U.S. 74, 78 (2005)(followed)
  • Erickson v. Pardus, 551 U.S. 89, 94 (2007) (per curiam)(followed)
  • Weller v. Department of Social Services, 901 F.2d 387, 391 (4th Cir. 1990)(followed)

Cited In (0)

No citing cases on record yet.

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