Cunningham v. Danville City Jail, 7:17-cv-00209

Plaintiff James E. Cunningham, a pro se Virginia inmate confined at Danville City Jail, sued the Jail and the City of Danville under 42 U.S.C. § 1983 alleging unconstitutional living conditions and denial of Hepatitis C treatment.
Complaints about conditions: fluorescent light causing eye damage, no outdoor recreation or windows, poor/no ventilation, bad-tasting water, foul smells, limited recreation, and lack of church services.
Plaintiff sought monetary damages and transfer to another facility; he separately moved to amend to add an Eighth Amendment claim for denial of Hepatitis C treatment.
Court screened the complaint under 28 U.S.C. § 1915A and applied the Twombly/Iqbal plausibility standard for pleadings.
The court concluded the Jail is not a "person" under § 1983 and dismissed claims against it; it also found Cunningham pleaded no facts showing a municipal policy or municipal culpability and dismissed the City.
The proposed amendment asserting denial of Hepatitis C treatment failed to allege facts showing a serious medical need or deliberate indifference and was denied as futile.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the Danville City Jail is a proper § 1983 defendant	Cunningham named the Jail as a defendant for the alleged conditions	Jail is not a "person" subject to suit under § 1983	Jail is not a § 1983 defendant; claims dismissed against it
Whether the City of Danville is liable under Monell for jail conditions	Cunningham alleges jail conditions violated his rights (seeks damages/transfer)	No facts allege an official municipal policy or decision causing the violations	Claims against the City dismissed for failure to plead municipal policy/causation
Whether proposed Hepatitis C treatment claim states an Eighth Amendment violation	Cunningham alleges denial of Hepatitis C treatment at the Jail	No factual allegations about symptoms, requests for care, timing, or resulting injury to show serious need or deliberate indifference	Motion to amend denied as futile; claim fails to state an Eighth Amendment claim
Whether alleged jail conditions state an Eighth Amendment conditions-of-confinement claim	Cunningham contends conditions (lighting, ventilation, lack of outside access) create harm	No facts showing officials knew of substantial risk of serious harm or that plaintiff suffered serious physical injury; allegations at most negligence	Conditions claims dismissed for failure to allege subjective knowledge and serious harm required under Farmer

Neitzke v. Williams, 490 U.S. 319 (frivolous claim lacks arguable basis in law or fact)
Bell Atlantic Corp. v. Twombly, 550 U.S. 544 (plaintiff must plead facts making claim plausible)
Monell v. Department of Social Services of City of New York, 436 U.S. 658 (municipal liability requires an official policy or custom)
Estelle v. Gamble, 429 U.S. 97 (deliberate indifference to serious medical needs violates the Eighth Amendment)
Farmer v. Brennan, 511 U.S. 825 (to state a conditions claim, prisoner must show officials knew of and disregarded substantial risk of serious harm)
Ashcroft v. Iqbal, 556 U.S. 662 (plaintiff must plead that each government-official defendant, through own actions, violated the Constitution)
County of Sacramento v. Lewis, 523 U.S. 833 (negligently inflicted harm does not constitute a constitutional violation)