Darin Jones v. County Jail CFCF, 610 F. App'x 167

Plaintiff Darin Jones, pro se and in forma pauperis, sued CFCF officers and a medical supervisor under 42 U.S.C. § 1983 and state negligence for injuries after falling from a top bunk that lacked a ladder or step.
Jones alleges he fell while climbing down, hit his head, lost consciousness, received immediate treatment at CFCF (medication and an ice pack), and was returned to his cell.
The following day Jones was transferred to SCI‑Graterford, where he received further examination and wrist x‑rays; he continued to allege ongoing headaches and left wrist pain.
Jones did not allege he had previously complained to CFCF staff about difficulty using the top bunk or requested a ladder/step.
The District Court dismissed the complaint under 28 U.S.C. § 1915(e)(2)(B)(i) for failure to state a constitutional claim; it appears to have declined supplemental jurisdiction over the state negligence claim.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether CFCF conditions (no ladder) and resulting fall state an Eighth Amendment conditions‑of‑confinement claim	Lack of ladder made top bunk unsafe and caused injury	Allegations show at most negligence; no deliberate indifference or prior notice	Dismissed — allegations insufficient to show a serious deprivation or deliberate indifference
Whether medical care after the fall rose to deliberate indifference	Post‑fall headaches and wrist pain indicate inadequate medical care	Plaintiff received immediate care, medication, and follow‑up; no facts showing deliberate indifference	Dismissed — care alleged was not deliberately indifferent, at most negligent
Whether state negligence claim should remain in federal court if federal claims dismissed	Plaintiff sought to pursue state negligence claim alongside § 1983 claim	Defendants opposed federal jurisdiction after dismissal of federal claims	District Court properly declined supplemental jurisdiction; dismissal not an abuse of discretion
Whether leave to amend should have been granted	Plaintiff implicitly sought to proceed on claims; amendment could cure defects	District Court found amendment futile given complaint's deficiencies	Leave to amend denied as futile; dismissal affirmed

Farmer v. Brennan, 511 U.S. 825 (Eighth Amendment requires prison officials to be deliberately indifferent to substantial risk of harm)
Whitley v. Albers, 475 U.S. 312 (conduct beyond mere lack of due care required for Eighth Amendment liability)
Estelle v. Gamble, 429 U.S. 97 (deliberate indifference to serious medical needs constitutes Eighth Amendment violation)
White v. Napolean, 897 F.2d 103 (only unnecessary and wanton infliction of pain or deliberate indifference gives rise to constitutional claim)
Rouse v. Plantier, 182 F.3d 192 (negligence or malpractice alone does not constitute deliberate indifference)
Lake v. Arnold, 232 F.3d 360 (standard of review for sua sponte dismissal under § 1915)
Nami v. Fauver, 82 F.3d 63 (pleading standards — accept allegations and reasonable inferences as true on review)
Grayson v. Mayview State Hosp., 293 F.3d 103 (leave to amend generally required unless amendment would be futile)
United Mine Workers v. Gibbs, 383 U.S. 715 (supplemental jurisdiction principles)
Figueroa v. Buccaneer Hotel, Inc., 188 F.3d 172 (abuse of discretion standard for declining supplemental jurisdiction)