Loveless v. Grady County District Attorneys Office, 5:24-cv-00992

Chris Elroy Loveless, an Oklahoma state prisoner, filed a 42 U.S.C. § 1983 lawsuit alleging unconstitutional conditions at the Grady County Detention Center due to the use of triple-stacked bunk beds over six feet high, claimed to be unsafe and in violation of various laws.
Loveless named as defendants several state and county entities and officials, seeking both injunctive relief and $300,000 in compensatory damages.
The magistrate judge (Judge Amanda Maxfield Green) recommended dismissal of all claims, reasoning that the state entities are not "persons" under § 1983 for damages, and that no constitutional violation was stated.
Loveless objected, arguing he sought prospective injunctive relief and that the bunk bed arrangement constituted cruel and unusual punishment under the Eighth (and Fourteenth) Amendment.
At the time of the ruling, Loveless was no longer housed at the Grady County Detention Center, rendering any injunctive claim moot regarding conditions there.
The district court conducted de novo review and accepted the magistrate’s recommendation as modified, dismissing the complaint with/without prejudice as appropriate.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Are state entities and officials suable under § 1983 for damages?	Loveless argued state entities and officials are liable under §1983.	State entities and officials are not “persons” under § 1983.	Not suable for damages under § 1983; dismissed with prejudice.
Has Loveless stated an Eighth Amendment claim for conditions of confinement?	Triple-stacked beds are unreasonably unsafe and constitute cruel and unusual punishment.	No specific constitutional violation; bunk beds not objectively or subjectively unconstitutional.	Complaint does not state a constitutional claim; dismissed without prejudice.
Is injunctive relief warranted under Ex parte Young?	Claims were brought for ongoing prospective relief against officials.	No ongoing injury; claims are frivolous as plaintiff is no longer at facility.	No effective relief possible; injunctive claims are moot and dismissed without prejudice.
Should the court exercise supplemental jurisdiction over state law claims?	Federal question remains, so court should exercise jurisdiction over negligence claim.	No federal claim remains, so no supplemental jurisdiction.	Declined supplemental jurisdiction; state law claims dismissed.

Will v. Mich. Dep’t of State Police, 491 U.S. 58 (States and state officials in official capacities are not "persons" under § 1983 for damages)
Monell v. Dep’t of Soc. Servs., 436 U.S. 658 (Local governments can only be liable under § 1983 for policies/customs that cause constitutional violations)
Farmer v. Brennan, 511 U.S. 825 (Establishes objective/subjective standard for Eighth Amendment conditions claims)
Ex parte Young, 209 U.S. 123 (Allows suits against state officials for prospective injunctive relief in federal law violations)
Rhodes v. Chapman, 452 U.S. 337 (Eighth Amendment requires that conditions not deprive inmates of minimal civilized measures of life's necessities)