Coleman v. Onuoha, 9:24-cv-03158

Stye L. Coleman, a federal inmate previously housed at FCI Bennettsville, filed a pro se complaint alleging constitutional violations by prison staff under Bivens v. Six Unknown Named Agents of Federal Bureau of Narcotics.
Coleman asserted claims for negligence, medical malpractice, and Eighth Amendment violations associated with his incarceration.
An error in the plaintiff’s Bureau of Prisons (BOP) inmate number (56104-056 vs. correct 54104-056) caused all court mailings, including orders and notices, to be returned as undeliverable.
The magistrate judge recommended dismissing the complaint for failure to state a claim and Coleman’s failure to cure deficiencies, but Coleman never received notice or opportunities to amend due to the inmate number mix-up.
The district court determined that the case should not be dismissed solely because of this clerical error and directed the clerk to update the records and re-mail the necessary documents to Coleman at FCI Beckley.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Validity of Bivens/negligence/medical claims	Constitutional & tort claims allowable	Not actionable under Bivens, insufficient facts	Magistrate: dismissal recommended; District Court: no dismissal due to notice issue
Inmate notification failure	N/A (pro se)	N/A	Case not dismissed due to ineffective notice resulting from clerical error
Inmate number accuracy	Complaint signed correctly (54104-056)	N/A	Record corrected; filings to be resent to proper inmate number
Leave to amend	Should be granted (implied)	Should not be granted	Plaintiff to be given a new opportunity to amend upon proper notice

Bivens v. Six Unknown Named Agents of Fed. Bureau of Narcotics, 403 U.S. 388 (1971) (establishes a cause of action for damages against federal officers alleged to have violated constitutional rights)
Goldfarb v. Mayor and City Council of Baltimore, 791 F.3d 500 (4th Cir. 2015) (court may take judicial notice of matters of public record)