Barrett v. State of Missouri, 2:19-cv-00027

Plaintiff Terrell Lee Barrett, a Missouri state prisoner, sued under 42 U.S.C. § 1983 seeking $5 million for alleged inadequate medical care for injuries to his left knee and left hand while incarcerated.
Defendants named: State of Missouri, Missouri Department of Corrections (MDOC), and Corizon Health Service (a private medical contractor).
Plaintiff alleges failures to treat recurrent knee injury (after prior surgery) and a “botched” hand operation, requiring subsequent surgeries. Allegations are largely conclusory and lack factual detail about specific acts or policies.
Plaintiff moved to proceed in forma pauperis; the court assessed an initial partial filing fee of $23.02 based on account statements.
The court conducted an initial review under 28 U.S.C. § 1915(e)(2) and dismissed the complaint without prejudice for failure to state a claim; appointment of counsel was denied as moot.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether State/MDOC can be sued under § 1983 for money damages	Barrett asserts the State and MDOC violated his § 1983 rights by providing inadequate medical care	State/MDOC are arms of the State and not "persons" under § 1983; Eleventh Amendment sovereign immunity bars suit	Dismissed: State and MDOC are not § 1983 "persons" and are immune from suit under the Eleventh Amendment
Whether Corizon is liable under § 1983	Barrett claims Corizon failed to provide constitutionally adequate medical care while acting under color of state law	Corizon requires allegations showing a policy, custom, or official action caused the violation; cannot be held liable on respondeat superior alone	Dismissed: Complaint fails to plead any policy/custom or plausible factual allegations against Corizon
Sufficiency of pleading under § 1915(e)(2) and Twombly/Iqbal standards	Barrett contends facts (injuries, surgeries, requests for care) show deliberate indifference	Defendants argue allegations are conclusory, speculative, and do not plead factual content to plausibly show deliberate indifference or a policy-based corporate liability	Dismissed: Court finds allegations are legal conclusions and vague; do not meet plausibility standard and must be dismissed
Motion for appointment of counsel	Barrett requested counsel to assist with prosecution	No substantive response needed if case is dismissed	Denied as moot because case dismissed under § 1915(e)(2)

Ashcroft v. Iqbal, 556 U.S. 662 (plausibility standard for complaints)
Will v. Michigan Dep’t of State Police, 491 U.S. 58 (states not "persons" under § 1983 for money damages)
Edelman v. Jordan, 415 U.S. 651 (Eleventh Amendment immunity from federal suits)
Quern v. Jordan, 440 U.S. 332 (§ 1983 does not abrogate state sovereign immunity)
McLean v. Gordon, 548 F.3d 613 (§ 1983 actions require a "person")
Johnson v. Hamilton, 452 F.3d 967 (corporate liability requires policy or custom causing injury)
Smith v. Insley’s Inc., 499 F.3d 875 (no respondeat superior liability for corporations under § 1983)
Torti v. Hoag, 868 F.3d 666 (courts need not accept legal conclusions couched as factual allegations)