BEST v. MARCUS O. HICKS
3:22-cv-06911-PGS-RLS
| D.N.J. | Jul 28, 2025Background
- John Best (Plaintiff), a former inmate at South Woods State Prison, filed a civil rights action under 42 U.S.C. § 1983 and the New Jersey Civil Rights Act (NJCRA) alleging excessive force and denial of medical care by corrections officers.
- The incident in question occurred when Best was placed on suicide watch and allegedly beaten by several corrections officers, resulting in significant injuries and delayed medical care.
- Plaintiff brought several claims, including supervisory liability against policymaker defendants for failure to supervise or train regarding excessive force and medical care (Count Eight), and a parallel claim under the NJCRA (Count Nine).
- The court previously dismissed Counts Three (part one), Four, Five, Six, Eight, and Nine without prejudice, leaving some claims pending.
- Plaintiff moved for reconsideration regarding Counts Eight and Nine, arguing the court failed to address his excessive force supervisory liability and NJCRA claims.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Supervisory liability for failure to supervise/train regarding excessive force (Count Eight) | Court failed to address the claim; supervisors should be liable for inadequate response to excessive force patterns | No specific policy, pattern, or notice alleged; conclusory facts insufficient | Dismissed without prejudice; no specific policy, training deficit, or pattern alleged |
| Supervisory liability for failure regarding medical care (Count Eight) | Supervisors failed to address inadequate medical care | No identified policy or pattern; complaint is conclusory | Dismissed without prejudice; failure to state a claim on supervisory liability |
| Reconsideration of dismissal of NJCRA claim (Count Nine) | Court didn't parse NJCRA claim for excessive force and failure to intervene remedies | Dismissal appropriate since related § 1983 claims were dismissed | Reconsideration denied; NJCRA claim dismissed as duplicative of failed § 1983 claim |
| Motion for reconsideration of prior dismissal order | Court failed to address all relevant claims in prior order | No new law or evidence; no clear error | Granted only to clarify scope of Count Eight's dismissal; otherwise denied |
Key Cases Cited
- Phillips v. County of Allegheny, 515 F.3d 224 (3d Cir. 2008) (standards on considering Rule 12 motions to dismiss)
- Barkes v. First Corr. Med., Inc., 766 F.3d 307 (3d Cir. 2014) (standards for supervisory liability under § 1983)
- Connick v. Thompson, 563 U.S. 51 (2011) (failure to train claims require pattern and notice)
- Beers-Capitol v. Whetzel, 256 F.3d 120 (3d Cir. 2001) (pattern and knowledge required for supervisory liability)