Fred Erin Dennison v. Sheriff John McMahon, 5:17-cv-02032

Plaintiff Fred Erin Dennison, a pretrial detainee, filed a pro se § 1983 suit alleging his cell light was nonfunctional for over 50 days, exacerbating his documented vision problems and delaying his criminal case.
Complaint names Sheriff John McMahon solely in his official capacity and seeks monetary damages for the alleged civil rights violation.
Plaintiff alleges McMahon was aware of the light problem and refused to have jail staff repair it despite being informed of Plaintiff’s vision issues and pro se status.
The Court screened the complaint under 28 U.S.C. §§ 1915(e)(2) and 1915A for failure to state a claim and for immunity barriers to damages.
The Court determined that an official-capacity claim against McMahon is treated as a suit against the governmental entity and that Plaintiff failed to plead municipal liability under Monell.
The Court dismissed the complaint for failure to state a claim but granted leave to amend, instructing Plaintiff that to pursue damages against McMahon individually he must expressly sue him in his individual capacity and file a complete First Amended Complaint within 30 days.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether naming the sheriff in his official capacity supports a damages claim	McDenson alleges McMahon (officially) is liable for deliberate refusal to repair cell light causing harm	Official-capacity suit is effectively against the government entity; municipal liability not pleaded	Dismissed: official-capacity damages claim fails without Monell allegations
Whether an inadequate lighting condition can support a constitutional conditions-of-confinement claim	Lack of cell light for 50+ days violated constitutional protection (impairing access/life/safety)	Implicit defense: no properly pleaded individual or municipal policy/failure to show constitutional violation as pleaded	Court recognizes inadequate lighting can be actionable but found pleading deficient here
Whether plaintiff stated a § 1983 claim against a person acting under color of state law	Plaintiff alleges McMahon was personally aware and refused to act	Court requires showing of individual capacity liability or municipal policy/custom causing violation	Court: complaint did not plead individual-capacity claim or Monell policy/custom allegations; thus insufficient
Whether dismissal should be with or without leave to amend	Plaintiff is pro se and factual defects may be curable	Defendant would rely on pleading defects and immunity where applicable	Court granted leave to amend, finding defects potentially curable; warned failure to amend may result in dismissal with prejudice

Monell v. Dep't of Soc. Servs., 436 U.S. 658 (1978) (municipalities liable under § 1983 only for constitutional violations resulting from an official policy or custom)
Will v. Michigan Dep't of State Police, 491 U.S. 58 (1989) (state officials sued in their official capacity are equivalent to suits against the state)
Kentucky v. Graham, 473 U.S. 159 (1985) (official-capacity suits are against the entity; personal-capacity relief differs)
Hoptowit v. Spellman, 753 F.2d 779 (9th Cir. 1985) (adequate lighting is a component of constitutionally adequate shelter)
Simmons v. Navajo County, 609 F.3d 1011 (9th Cir. 2010) (pretrial detainee conditions claims are analyzed under Due Process but similar standards to Eighth Amendment)
Bell Atlantic Corp. v. Twombly, 550 U.S. 544 (2007) (plausibility pleading standard required to state a claim)
Ashcroft v. Iqbal, 556 U.S. 662 (2009) (requirement that factual allegations must permit a reasonable inference of liability)
Balistreri v. Pacifica Police Dep't, 901 F.2d 696 (9th Cir. 1990) (complaint may be dismissed for lack of cognizable legal theory or insufficient facts)