Thomas Jeff Henry v. S.W.V.R.J. — Duffield

Summary

The United States District Court for the Western District of Virginia dismisses Thomas Jeff Henry’s 42 U.S.C. § 1983 complaint under 28 U.S.C. § 1915A for failure to state a claim. The court concludes that the named jail is not a person subject to suit under § 1983 and that the complaint contains only conclusory allegations without factual details regarding the alleged unlawful arrest or civil-rights violations.

Holdings

1. A jail is not a person within the meaning of 42 U.S.C. § 1983 and lacks the capacity to be sued under that statute.
2. A § 1983 complaint must provide factual allegations supporting an entitlement to relief, including facts identifying the alleged constitutional violation and, where applicable, each defendant's personal involvement; conclusory assertions that an arrest was unlawful and rights were violated are insufficient.

Questions Presented

1. Whether the complaint stated a claim under 42 U.S.C. § 1983 against the named jail.
2. Whether the complaint contained sufficient factual allegations to state a claim for relief under § 1983.

Disposition

dismissed