Cornelius v. Shawano County Jail, 2:24-cv-00499

Bruce G. Cornelius, Jr., a former inmate at Shawano County Jail, filed a pro se complaint under 42 U.S.C. §1983 alleging constitutional violations.
The complaint centers on an incident where Cornelius, classified as a medium-security detainee, was attacked by a known dangerous maximum-security inmate after officers allowed him out of his cell without ensuring others were secured.
Cornelius alleged jail staff failed to adequately check cell doors, enabling the attack and causing him physical harm.
The complaint named Shawano County Jail and two officers as defendants; Cornelius sought compensatory and punitive damages.
The court first granted Cornelius’s request to proceed in forma pauperis but then screened the complaint under the Prison Litigation Reform Act (PLRA).
The court dismissed the complaint for failure to state a claim upon which relief can be granted, issuing Cornelius a "strike" under 28 U.S.C. §1915(g).

Issue	Plaintiff's Argument	Defendant's Argument	Held
Can a jail be sued under § 1983?	Jail liable as entity responsible for his safety.	Jail is not a "person" and not subject to suit.	Jail cannot be sued under § 1983.
Did officers fail to protect under the Fourteenth Amendment?	Officers acted unreasonably by not ensuring cell security, enabling attack.	Officers had no specific knowledge of heightened risk; general risks not enough.	No Fourteenth Amendment violation; no plausibly alleged notice or reckless disregard.
Is negligence sufficient for a constitutional claim?	Lax security, allowing attack, establishes constitutional violation.	Only reckless disregard, not negligence, meets the Fourteenth Amendment standard.	Negligence is insufficient for constitutional claim—must show reckless disregard.
Is amendment of the complaint warranted?	Sufficient factual allegations, or could be improved.	Amendment would be futile as facts do not meet the legal standard.	Amendment futile; complaint dismissed without leave to amend.

Monell v. Dep't of Social Services of City of New York, 436 U.S. 658 (individuals can sue municipalities, not arms of government like jails themselves)
Ashcroft v. Iqbal, 556 U.S. 662 (pleading standards for plausibility in federal court)
Bell Atlantic Corp. v. Twombly, 550 U.S. 544 (standard for plausibility in pleadings)
Bell v. Wolfish, 441 U.S. 520 (pretrial detainees' due process rights under Fourteenth Amendment)
Whiting v. Marathon County Sheriff's Dep't, 382 F.3d 700 (jails and sheriff's departments not legal entities separable from counties for §1983)