Goins v. T.D.O.C.
1:25-cv-00089
E.D. Tenn.Jun 5, 2025Background
- Daniel Goins, a Tennessee state prisoner, filed a pro se civil rights lawsuit under 42 U.S.C. § 1983, alleging various constitutional violations during his time at two correctional facilities.
- The Court previously instructed Goins to submit an amended complaint containing only properly joined claims, advising that only the first claim and those properly joined with it would remain if not corrected.
- Goins’ amended complaint named several defendants from both Bledsoe County Correctional Complex (BCCX) and Morgan County Correctional Complex (MCCX), and listed claims arising from both facilities.
- The primary claim screened by the Court involved Officer Andrew Schults at BCCX, for alleged deliberate indifference to medical needs and other mistreatment.
- Goins also sought relief against the Tennessee Department of Correction (TDOC), food provider Aramark, and medical provider Centurion, but did not allege sufficient facts tying his injuries to these entities’ policies or customs.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Deliberate indifference to medical needs | Schults ignored heart problems, refused to help | Lack of detail on medical need and Schults’ actual knowledge | Dismissed – not plausible |
| Denial of adequate food/nutrition | Schults played with/refused to serve food, causing harm | No specifics or alleged harm from inadequate nutrition | Dismissed – no harm shown |
| Liability of TDOC under § 1983 | TDOC responsible as employer | States not "persons" under § 1983 and immune under 11th Amend. | Dismissed – immune |
| Liability of Aramark/Centurion (policy/custom) | Responsible for harm via institutional practices | No policy/custom alleged as cause of harm | Dismissed – no support |
Key Cases Cited
- Estelle v. Gamble, 429 U.S. 97 (1976) (establishes standard for deliberate indifference to prisoners’ serious medical needs)
- Farmer v. Brennan, 511 U.S. 825 (1994) (explains deliberate indifference requires knowledge and disregard of excessive risk)
- Wilson v. Seiter, 501 U.S. 294 (1991) (Eighth Amendment only covers unnecessary and wanton infliction of pain)
- Ashcroft v. Iqbal, 556 U.S. 662 (2009) (sets standard for plausibility of claims in pleadings)
- Bell Atl. Corp. v. Twombly, 550 U.S. 544 (2007) (pleading must state a plausible claim, not just legal conclusions)
- Will v. Mich. Dep’t of State Police, 491 U.S. 58 (1989) (states and state agencies not “persons” for § 1983 purposes)
- Cunningham v. Jones, 567 F.2d 653 (6th Cir. 1977) (prisoner’s diet must harm health to create claim)