Henry v. Paige
7:24-cv-00145
W.D. Va.Apr 18, 2024Background
- Daniel A. Henry, a Virginia jail inmate, filed a pro se civil rights complaint under 42 U.S.C. § 1983.
- Henry alleged he was assaulted by his intoxicated cell mate while on mental health and seizure medication.
- He named as defendants his cell mate, three individuals (Paige, Sullivan, Jenkins), the Virginia Department of Corrections (VDOC), and Wallens Ridge State Prison (WRSP).
- Henry requested $3.3 million in damages, expungement of records, and release from prison.
- The court reviewed the complaint to determine if it sufficiently stated a plausible claim for relief under § 1983.
- The case was summarily dismissed for failure to state a claim.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Sufficiency of allegations under § 1983 | Alleged cell mate beat him; seeks damages and release | Not directly stated; based on record | Complaint fails to state facts against any defendant |
| Personal involvement of defendants | Names several individuals/entities as defendants | Not directly stated; based on record | No allegations of specific acts by named defendants |
| Liability of state entities under § 1983 | Listed VDOC/WRSP as defendants | Not directly stated; based on record | VDOC/WRSP cannot be sued under § 1983 |
| State action requirement for § 1983 suit | May have intended to sue inmate attacker | Not directly stated; based on record | Inmate attacker not a state actor for § 1983 purposes |
Key Cases Cited
- Cooper v. Sheehan, 735 F.3d 153 (4th Cir. 2013) (Section 1983 allows suits only for deprivation of constitutional rights under color of state law)
- Giarratano v. Johnson, 521 F.3d 298 (4th Cir. 2008) (Complaint must state specific facts making a plausible claim)
- Will v. Mich. Dep’t of State Police, 491 U.S. 58 (1989) (The state cannot be sued under § 1983)
- Lugar v. Edmondson Oil Co., 457 U.S. 922 (1982) (Section 1983 requires violation under color of state law)