Brandy Hood-Cook v. SWVRJA-Duffield Facility, et al.

Summary

The United States District Court for the Western District of Virginia dismisses Brandy Hood-Cook’s 42 U.S.C. § 1983 action against the Southwest Virginia Regional Jail Authority’s Duffield Facility and its Records Department. The court holds that the jail is not a suable person under § 1983 and that claims challenging sentence calculation and release eligibility must be pursued through habeas corpus rather than a civil rights action.

Holdings

1. A local jail facility is not a person subject to suit under § 1983 and lacks capacity to be sued as a jail. Hood-Cook's lockdown-policy claim therefore failed because it was asserted against the Duffield Facility.
2. A claim challenging the calculation of a sentence or the date of release must be brought in habeas corpus rather than under § 1983 because § 1983 is not the proper vehicle to challenge the fact or duration of confinement.
3. The complaint failed to state a claim upon which relief could be granted and was subject to summary dismissal without prejudice under 28 U.S.C. § 1915A(b)(1).

Questions Presented

1. Whether a local jail facility is a person subject to suit under 42 U.S.C. § 1983.
2. Whether a prisoner's challenge to the calculation of her sentence and release date may be brought under § 1983 rather than through habeas corpus.
3. Whether the complaint stated a claim upon which relief could be granted under the screening standard of 28 U.S.C. § 1915A(b)(1).

Disposition

dismissed