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