Alvarado 931694 v. Unknown Party, 1:25-cv-00124

Background

Plaintiff Jorge Antonio Lopez Alvarado, an incarcerated individual, filed a civil rights lawsuit under 42 U.S.C. § 1983 against various correctional and medical staff at Earnest C. Brooks Correctional Facility, Michigan, alleging deliberate indifference to his serious medical needs following major face surgery.
Plaintiff reported numerous incidents over a roughly one-week period where he requested medical care, pain medication, and ice to manage pain and swelling but was denied or ignored by staff.
The case is at the preliminary screening stage under the Prison Litigation Reform Act (PLRA), requiring the court to dismiss claims that fail to state a claim before service on defendants.
Plaintiff consented to have his case conducted by a Magistrate Judge, but since defendants have not been served, only plaintiff’s consent was relevant.
Plaintiff named multiple defendants in individual and official capacities but sought monetary damages only.
The court reviewed both the federal (Eighth Amendment) and state law claims, and conducted an individual analysis of each defendant’s alleged conduct.

Issues

Issue	Plaintiff’s Argument	Defendant’s Argument	Held
Whether Plaintiff stated a claim under § 1983 against defendants in their official capacities	Defendants violated Eighth Amendment by denying/delaying medical care	State and MDOC are immune under the Eleventh Amendment; no Monell policy/custom pled for private medical providers	Official capacity claims dismissed for all MDOC staff; dismissed for private contractors for failure to allege policy/custom
Whether Plaintiff stated an individual capacity Eighth Amendment claim for deliberate indifference	Named defendants were deliberately indifferent to post-surgical serious medical needs	Defendants: Responded to requests when aware; lack of personal involvement or knowledge; at most, mere disagreement over care	All but one Eighth Amendment claim dismissed for failure to allege deliberate indifference, except against Officer Stewart for one specific incident
Whether Plaintiff stated a claim against Warden King under § 1983	King as supervisor is liable for his subordinates’ actions	Supervisory liability barred unless active unconstitutional behavior is shown	Claim against King dismissed for lack of specific allegations or personal involvement
Whether the court should exercise supplemental jurisdiction over state law claims	State law torts (e.g., medical negligence) arise from the same facts	Judicial economy must be balanced with needlessly deciding state law issues	Court declines to retain jurisdiction over state law claims except those against Stewart, as only claims against Stewart survive

Key Cases Cited

Estelle v. Gamble, 429 U.S. 97 (1976) (establishing that deliberate indifference to a serious medical need violates the Eighth Amendment).
Bell Atl. Corp. v. Twombly, 550 U.S. 544 (2007) (pleading standard for stating a claim under Rule 8).
Ashcroft v. Iqbal, 556 U.S. 662 (2009) (clarifying plausibility pleading standard under Rule 8).
Farmer v. Brennan, 511 U.S. 825 (1994) (defines deliberate indifference under the Eighth Amendment).
Will v. Michigan Dep’t of State Police, 491 U.S. 58 (1989) (states are not “persons” who can be sued for money damages under § 1983).
Monell v. Dep’t of Soc. Servs., 436 U.S. 658 (1978) (municipal liability under § 1983 requires policy or custom).