Kenneth Roberts v. River Correctional Center, et a
698 F. App'x 184
| 5th Cir. | 2017Background
- Kenneth Roberts, a Louisiana prisoner, sued River Correctional Center (RCC), Sheriff Kenneth Hedrick, and unnamed RCC medical staff under 42 U.S.C. § 1983 alleging Eighth Amendment deliberate indifference to serious medical needs.
- The district court dismissed the complaint sua sponte for failure to state a claim under 28 U.S.C. §§ 1915(e)(2)(B) and 1915A.
- Roberts repeatedly characterized his claim as medical negligence rather than constitutional deliberate indifference.
- He alleged inadequate care by RCC medical staff and suggested possible retaliation by a nurse related to a prior grievance, but provided few factual allegations to support that claim.
- Roberts asserted RCC and Sheriff Hedrick were liable for employees’ actions by virtue of supervisory responsibility and sought discovery before dismissal.
- The Fifth Circuit reviewed the dismissal de novo and evaluated whether Roberts’ allegations, taken as true, could state an Eighth Amendment claim.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether allegations state Eighth Amendment deliberate indifference | Roberts contends medical care amounted to constitutional inadequate care | Defendants maintain allegations show negligence/medical malpractice, not constitutional indifference | Dismissed: allegations fit negligence, not deliberate indifference |
| Whether nurse’s actions were retaliatory | Roberts alleges nurse retaliated for a prior grievance | Defendants say no factual basis for retaliation inference | Dismissed: no facts supporting retaliation claim |
| Whether RCC and Sheriff Hedrick are liable for staff conduct | Roberts argues institutional/supervisory liability for employees’ actions | Defendants argue liability cannot be imposed solely on respondeat superior grounds | Dismissed: supervisory liability not established by pleaded facts |
| Whether dismissal without permitting discovery was improper | Roberts requested discovery before dismissal | Defendants relied on Rule 12(b)(6) standard and sufficiency of pleadings | Denied: dismissal was proper under Rule 12(b)(6) jurisprudence |
Key Cases Cited
- Velasquez v. Woods, 329 F.3d 420 (5th Cir. 2003) (standard of review for sua sponte dismissal under § 1915)
- Samford v. Dretke, 562 F.3d 674 (5th Cir. 2009) (Rule 12(b)(6) standard applied to dismiss for failure to state a claim)
- Sama v. Hannigan, 669 F.3d 585 (5th Cir. 2012) (Eighth Amendment deliberate indifference standard for medical claims)
- Farmer v. Brennan, 511 U.S. 825 (1994) (deliberate indifference test in prison conditions cases)
- Stewart v. Murphy, 174 F.3d 530 (5th Cir. 1999) (distinguishing negligence/medical malpractice from deliberate indifference)
- Gentilello v. Rege, 627 F.3d 540 (5th Cir. 2010) (need for allegations showing knowledge of substantial risk and disregard)
- Thompson v. Upshur Cnty., 245 F.3d 447 (5th Cir. 2001) (supervisory liability cannot rest on respondeat superior)
- Southwestern Bell Tel., LP v. City of Houston, 529 F.3d 257 (5th Cir. 2008) (Rule 12(b)(6) dismissal and discovery contention)