Chad Langford v. Hector Joyner, 62 F.4th 122

In March 2018 Langford, while incarcerated at FCI Estill, experienced abdominal pain, nausea, and vomiting and was taken to Hampton Regional Medical Center (HRMC); initial testing was reported as unremarkable and he was returned to prison.
From March 20–28 his condition worsened: severe pain, limited mobility (wheelchair, assistance from inmates), uncontrollable diarrhea, and repeated trips to the prison medical office where he alleges he was refused examination or treatment.
On March 28 a substitute physician ordered an examination and sent Langford back to HRMC for emergency surgery; he was diagnosed with a small bowel obstruction and abdominal infection and alleges permanent injury.
In March 2021 Langford filed a single-count Bivens suit alleging Eighth Amendment deliberate indifference against multiple FCI Estill officials (warden, two nurses, case manager, unit manager, and unnamed officials).
The district court dismissed the complaint under Fed. R. Civ. P. 12(b)(6) for failure to state a plausible claim; Langford appealed to the Fourth Circuit.
The Fourth Circuit affirmed, holding Langford failed to plead sufficient, individualized facts showing each defendant had actual subjective knowledge of his serious medical need and the risk posed by inaction.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether Langford pleaded a plausible Eighth Amendment deliberate-indifference Bivens claim	Langford argues his repeated complaints and visible deterioration, alleged against all "Defendants," suffice to show deliberate indifference by each defendant	Defendants argue the complaint makes only generalized, collective allegations and fails to identify each defendant's personal involvement or knowledge	Court held the complaint failed: plaintiffs must plead facts plausibly showing each government official’s individual culpable state of mind; collective allegations were insufficient
Whether collective references to "Defendants" can substitute for individualized allegations	Langford contends using "Defendants" as shorthand is adequate because same facts apply to each defendant	Defendants contend group pleading gives no fair notice and cannot support personal Bivens liability	Court held collective pleading may sometimes suffice in context but not here; facts did not permit reasonable inference that each named nonmedical and medical defendant knew of the condition and risk

Ashcroft v. Iqbal, 556 U.S. 662 (2009) (pleading must contain factual content permitting plausible inference of each defendant’s individual liability)
Bell Atlantic Corp. v. Twombly, 550 U.S. 544 (2007) (complaint must state a claim that is plausible on its face)
Mays v. Sprinkle, 992 F.3d 295 (4th Cir. 2021) (Rule 12(b)(6) review standards in Fourth Circuit)
Jackson v. Lightsey, 775 F.3d 170 (4th Cir. 2014) (framework for objective and subjective elements of Eighth Amendment medical claims)
Farmer v. Brennan, 511 U.S. 825 (1994) (deliberate indifference requires subjective awareness of substantial risk)
Bivens v. Six Unknown Named Agents, 403 U.S. 388 (1971) (establishes judicially-created remedy for constitutional violations by federal officials)
Trulock v. Freeh, 275 F.3d 391 (4th Cir. 2001) (Bivens liability is personal and based on each defendant’s own acts)
Robbins v. Oklahoma, 519 F.3d 1242 (10th Cir. 2008) (criticizes complaints that fail to isolate each defendant’s alleged unconstitutional acts)
Marcilis v. Twp. of Redford, 693 F.3d 589 (6th Cir. 2012) (rejects categorical references to "Defendants" without individualized allegations)
SD3, LLC v. Black & Decker (U.S.) Inc., 801 F.3d 412 (4th Cir. 2015) (criticizes vague, non-specific group allegations against multiple defendants)