Jeffery R. Bell v. C.K. Landress, 708 F. App'x 138

Plaintiff Jeffery R. Bell, a Virginia Beach jail inmate, sued under 42 U.S.C. § 1983 alleging Deputy Landress used excessive force: slamming Bell’s hand/arm in a food-tray slot and repeatedly spraying pepper spray after Bell asked to speak to a supervisor.
Bell attached to his complaint an incident report authored by Deputy Landress describing the events from Landress’s perspective.
The district court treated the attached report as true and applied the Rule 12(b)(6) standard, concluding Bell failed to state an excessive-force claim and dismissing the complaint under 28 U.S.C. § 1915A(b)(1).
The Fourth Circuit reviewed whether the district court properly treated the attachment as adopting its contents as true for pleading purposes.
The Fourth Circuit held the report was a unilateral, defendant-prepared document reflecting Landress’s version of events and Bell did not rely on it to form his claim; thus it was error to accept the report as true.
The Fourth Circuit vacated the dismissal and remanded for further proceedings.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether a plaintiff’s attachment of a defendant-authored incident report means the plaintiff adopted the report’s factual statements as true for Rule 12(b)(6) purposes	Bell argued he did not adopt the report as true; he attached it but relied on his own allegations of excessive force	Landress (via district court) contended the attached report must be taken as true, negating the excessive-force claim	Court held attachment alone does not require adopting contents as true; district court erred in treating the report as conclusive because Bell did not rely on it to form his claim
Whether the complaint states an excessive-force claim when the district court relies on the attached report	Bell asserted his allegations suffice to state a claim regardless of the report	District court found report’s facts defeated the claim and dismissed under § 1915A(b)(1)	Vacated and remanded: dismissal was premised on improper factual adoption of the report; merits must be reassessed without treating the report as true

Goines v. Valley Cmty. Servs. Bd., 822 F.3d 159 (4th Cir. 2016) (court explained that a plaintiff does not necessarily adopt the truth of an attached document and that district courts should consider the nature and purpose of attachments, especially unilateral defendant-prepared documents)