Dobbins v. Adams
5:17-cv-00210
E.D. Ark.Sep 19, 2017Background
- Plaintiff Charles Dobbins, a convicted inmate at W.C. “Dub” Brassell Adult Detention Center, sued under 42 U.S.C. § 1983 claiming he was housed in the wrong pod and attacked by other inmates.
- Court previously granted in forma pauperis status and ordered an amended complaint, noting the Jail is not a suable entity and that original allegations were insufficient against Defendant Adams.
- Amended Complaint reiterated the attack facts but did not allege Adams knew of a specific risk to Dobbins or that Adams took actions showing deliberate indifference.
- The Amended Complaint named the detention center (Dub Brassell Detention Center) as a defendant and retained Adams but failed to allege facts tying Adams to the risk or custody decision creating the risk.
- The magistrate judge screened the complaint under the PLRA and § 1915A and recommended dismissal for failure to state a claim; dismissal to count as a PLRA "strike" and in forma pauperis appeal not in good faith.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether Adams violated Eighth Amendment by failing to protect Dobbins | Dobbins asserts he was housed in the wrong pod and was attacked | Adams (as alleged) not shown to have known of or disregarded a substantial risk | Dismissed — no deliberate-indifference facts alleged against Adams |
| Whether the detention center is a proper § 1983 defendant | Dobbins named the Jail as a defendant | The Jail is an administrative subdivision/entity not subject to suit | Dismissed — detention center not a suable juridical entity |
| Whether the Amended Complaint meets federal pleading standards | Factual allegations describe attack but lack causal facts tying defendants to constitutional violation | Defendants argue pleadings insufficient under Twombly/Iqbal and PLRA screening | Dismissed — complaint fails to plausibly allege liability |
| Whether dismissal should count as a PLRA strike and affect IFP appeal rights | N/A (procedural consequence of dismissal) | N/A | Recommended: dismissal constitutes a PLRA "strike" and IFP appeal would not be in good faith |
Key Cases Cited
- Neitzke v. Williams, 490 U.S. 319 (frivolousness standard for prisoner suits)
- Bell Atlantic Corp. v. Twombly, 550 U.S. 544 (pleading must state a plausible claim)
- Ashcroft v. Iqbal, 556 U.S. 662 (plausibility standard and requirement to plead specific facts)
- Nelson v. Shuffman, 603 F.3d 439 (8th Cir.) (deliberate indifference standard for failure-to-protect claims)
- Dean v. Barber, 951 F.2d 1210 (11th Cir.) (municipal/subdivision entities like departments not suable separate juridical entities)