Maloch v. Salt Lake County Metro Jail, 2:12-cv-01084

Maloch, a pro se prisoner, filed a 1983 civil rights complaint in forma pauperis in the District of Utah.
Court screening identifies deficiencies and orders amendment to cure them before proceeding.
Defendants incorrectly named Salt Lake County Metro Jail as a separate entity capable of suit.
Plaintiff’s claims lack a proved municipal policy or custom linking Salt Lake County to alleged rights violations.
Court notes Heck v. Humphrey may require dismissal of claims that would imply invalidation of a conviction or sentence.
Order directs 30-day cure period and provision of the Pro Se Litigant Guide; failure to cure will result in dismissal.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the jail can be sued as a separate entity	Maloch argues the jail is the proper defendant.	The jail is not a separate legal entity; the claims should be against Salt Lake County.	Claims fail to state against the county.
Whether the claim states municipal-liability under §1983	Plaintiff asserts county liability for a policy or custom.	Plaintiff has not shown a direct causal link between policy and violation.	No direct policy link shown; failure to state a Monell claim.
Whether Heck bars the claims seeking relief that would imply invalidation of conviction	Plaintiff seeks damages for rights violations arising from imprisonment.	If relief would imply invalid conviction, Heck bars the claim.	Claims may be dismissed if conviction not already invalidated.
Whether Plaintiff must amend with proper pleadings and personal participation	Plaintiff should be allowed to amend.	Supervisory liability requires personal participation; mere supervisory position is insufficient.	Amendment required; must plead personal participation and specific conduct.

City of Canton v. Harris, 489 U.S. 378 (1989) (establishes municipal liability requires policy or custom and causal link)
Monell v. Dep't of Soc. Servs., 436 U.S. 658 (1978) (municipal liability requires policy or custom, not respondeat superior)
Cannon v. City and County of Denver, 998 F.2d 867 (10th Cir. 1993) (Monell-type liability; limits on supervisory liability)
Jenkins v. Wood, 81 F.3d 988 (10th Cir. 1996) (requires direct causal link between custom/policy and violation)
Mitchell v. Maynard, 80 F.2d 1433 (10th Cir. 1996) (supervisory liability not established by position alone)
Hall v. Bellmon, 935 F.2d 1106 (10th Cir. 1991) (pro se pleadings must meet basic pleading standards)