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Mays v. Hudgins
3:20-cv-00181
N.D.W. Va.
Aug 13, 2021
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Background

  • Plaintiff Joseph Randolph Mays, a federal inmate, sued multiple BOP officials and the United States alleging constitutional harms related to drinking water quality at FCI Gilmer and a conspiracy to delay or refuse to respond to his regional/central grievances.
  • Defendants moved to dismiss; the matter was referred to Magistrate Judge Trumble, who issued a Report & Recommendation (R&R) recommending dismissal.
  • Mays filed extensive filings (including a 65‑page response) and timely objections to the R&R but did not present new material facts.
  • The district court reviewed the record, found no new material facts in the objections, and concluded de novo review was unnecessary.
  • The court adopted the R&R, granted Defendants’ motion to dismiss: dismissed with prejudice as to Alicia Wilson, Eddie Anderson, and the United States; dismissed without prejudice as to the remaining individual defendants.
  • Plaintiff’s non‑dispositive motions (motion to compel, motion to strike, motion for excess pages, motion for joinder) were denied or denied as premature; a defendants’ motion to strike was terminated as moot.

Issues

Issue Plaintiff's Argument Defendant's Argument Held
Whether the complaint sufficiently alleges constitutional claims about drinking water conditions Mays contended the water conditions violated his constitutional rights Defendants argued the complaint failed to state a claim warranting relief Court dismissed the water‑quality claims (motion to dismiss granted)
Whether the complaint adequately alleges a conspiracy to delay/refuse grievance responses Mays alleged a conspiratorial scheme at regional and central offices Defendants argued the allegations were conclusory/insufficient Conspiracy claims dismissed for failure to state a claim
Whether the district court must perform de novo review of the magistrate judge’s R&R given Mays’s objections Mays objected to the R&R and sought de novo review Defendants argued objections lacked new material facts and specificity so de novo review not required Court declined de novo review and applied the R&R (objections insufficient)
Disposition of Mays’s miscellaneous motions (compel, strike, excess pages, joinder) Mays sought discovery relief, to strike language, leave for excess pages, and joinder Defendants opposed; procedural rules and timing cited Motions denied (joinder denied as premature; motion to strike/compel/leave denied; motion to strike by defendants terminated as moot)

Key Cases Cited

  • Thomas v. Arn, 474 U.S. 140 (1985) (standard for district court review of magistrate judge recommendations)
  • Snyder v. Ridenour, 889 F.2d 1363 (4th Cir. 1989) (failure to timely object waives right to de novo review)
  • United States v. Schronce, 727 F.2d 91 (4th Cir. 1984) (objections to magistrate recommendations)
  • Orpiano v. Johnson, 687 F.2d 44 (4th Cir. 1982) (scope of objections to magistrate reports)
  • Mario v. P & C Food Markets, Inc., 313 F.3d 758 (2d Cir. 2002) (specificity required in objections to preserve issues)
  • Camby v. Davis, 718 F.2d 198 (4th Cir. 1983) (no explanation required when adopting R&R absent objections)
  • Green v. Rubenstein, 644 F. Supp. 2d 723 (S.D. W. Va. 2009) (general or conclusory objections insufficient for de novo review)
  • Taylor v. Astrue, 32 F. Supp. 3d 253 (N.D.N.Y. 2012) (reiteration of prior arguments does not entitle a party to de novo review)
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Case Details

Case Name: Mays v. Hudgins
Court Name: District Court, N.D. West Virginia
Date Published: Aug 13, 2021
Docket Number: 3:20-cv-00181
Court Abbreviation: N.D.W. Va.