Ronnie Keith Brooking v. Central Virginia Regional Jail, et al.

Summary

The United States District Court for the Western District of Virginia dismissed Ronnie Keith Brooking’s 42 U.S.C. § 1983 action under 28 U.S.C. § 1915A(b)(1). The court held that the complaint failed to state a claim against the jail and other defendants and dismissed the action after Brooking failed to file an amended complaint addressing previously identified deficiencies.

Holdings

1. A jail is not a person within the meaning of § 1983 and therefore cannot be liable under that statute.
2. A § 1983 complaint must allege facts showing each defendant's personal involvement in the asserted constitutional violation; the complaint failed to do so and therefore stated no plausible claim against the remaining defendants.
3. The court must dismiss a prisoner's complaint that fails to state a claim upon which relief may be granted; dismissal was warranted because the original complaint remained deficient and plaintiff failed to file an amended complaint.

Questions Presented

1. Whether the complaint stated a claim under 42 U.S.C. § 1983 against the Central Virginia Regional Jail, which is not a person subject to suit under the statute.
2. Whether the complaint stated plausible § 1983 claims against the remaining defendants when it failed to allege each defendant's personal involvement.
3. Whether dismissal under 28 U.S.C. § 1915A(b)(1) was appropriate after plaintiff failed to amend the deficient complaint.

Disposition

dismissed