Fox v. King County Jail - DAJD
2:25-cv-00989
W.D. Wash.Jun 2, 2025Background
- Plaintiff Joshua G. Fox, an inmate at Monroe Correctional Complex, filed a pro se civil rights complaint under 42 U.S.C. § 1983, alleging inadequate medical care and unsafe conditions while previously housed at King County Jail.
- Fox had a below-the-knee amputation on June 6, 2022, and alleges that upon returning to the jail, he fell in the shower (due to lack of handrails or mats) and re-injured himself, missing medical follow-ups as well.
- Plaintiff claims these failures led to additional surgeries.
- Fox named only King County Jail – DAJD and Public Health/Jail Health Services as defendants, without identifying or implicating specific individuals.
- The district court screened the complaint as required under the PLRA (28 U.S.C. § 1915A) and found that it lacked sufficient factual allegations to state a claim and did not name proper defendants.
- The court declined to serve the complaint but allowed Fox to amend and correct the deficiencies by a set deadline.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Sufficiency of Pleading | Jail failed to provide adequate care and safety. | Not stated (screening issue) | Complaint fails to state a claim—no individuals or specific acts named. |
| Proper Defendant | Named King County Jail and Public Health/Jail Health. | Not stated | These are not legal entities that can be sued under § 1983. |
| Liability of Municipality | (Implied municipality liability for harm) | Not at issue (not properly named) | Plaintiff must show policy/custom caused violation, which is not alleged. |
| Constitutional Provision | Eighth Amendment violation alleged | Not at issue | Fourteenth Amendment applies to pretrial detainee, not Eighth Amendment. |
Key Cases Cited
- Monell v. New York City Dept. of Social Services, 436 U.S. 658 (municipal liability requires policy or custom causing constitutional violation)
- City of Canton v. Harris, 489 U.S. 378 (municipality liability under § 1983 requires deliberate indifference policy)
- Albright v. Oliver, 510 U.S. 266 (plaintiff must identify specific constitutional right violated)
- Leer v. Murphy, 844 F.2d 628 (must show personal participation of individual defendants)
- Johnson v. Duffy, 588 F.2d 740 (individual liability for affirmative act, participation, or omission)