Mueller v. Correction Care Solutions, 4:17-cv-03091

Background

Plaintiff Jason Mueller, a former Lancaster County Jail detainee, filed a § 1983 suit alleging denial of psychiatric medications for about two months during an August–November 2014 incarceration.
Defendants named: Correct Care Solutions (medical contractor), Joline Herrell, Dr. Charles Zaylor, and Jail Director Brad Johnson; individual and official-capacity claims were asserted.
Plaintiff claims intake staff failed to record his diagnosis (schizoaffective bipolar II) and did not restart his psychiatric meds despite his requests, kites, a mental-health appointment, a grievance, and a tort claim. He received medications before release.
He seeks $1,000,000 in actual and punitive damages for mental stress; he does not allege any physical injury.
The court conducted an initial review under 28 U.S.C. §§ 1915(e) and 1915A and found the complaint deficient for failure to plead municipal/contractor policy or customs and lack of facts showing personal involvement by the individual defendants. The court granted leave to amend by a set deadline.

Issues

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether county or contractor (official-capacity) defendants can be liable without alleging a policy/custom causing the violation	Mueller alleges denial of meds by jail/medical staff and names county and contractor in official capacities	County/contractor liability requires a policy, custom, or deliberately indifferent policymaker conduct	Dismissal of official-capacity claims for failure to allege a policy/custom; leave to amend granted
Whether individual defendants are liable in their individual capacities without pleaded personal involvement	Mueller names individuals and alleges they denied meds but gives no specific acts by each defendant	Individual liability requires allegations showing each defendant’s personal involvement/responsibility	Dismissal of individual-capacity claims for failure to plead personal involvement; leave to amend granted
Whether mental/emotional distress damages are recoverable without physical injury under PLRA	Mueller seeks compensatory damages for mental stress from denial of meds	PLRA bars compensatory/actual damages for mental or emotional injury absent physical injury	Court warns Plaintiff that absent physical injury he cannot recover compensatory damages (nominal, punitive, injunctive, declaratory still available)
Sufficiency of pro se pleading under Twombly/Iqbal standards	Mueller’s pro se status argues for liberal construction of his complaint	Defendants/standards require factual allegations to make claims plausible, not merely conceivable	Court applies Twombly/Iqbal; finds allegations insufficient to state a plausible § 1983 claim but allows amendment

Key Cases Cited

Bell Atlantic Corp. v. Twombly, 550 U.S. 544 (2007) (plausibility pleading standard)
Ashcroft v. Iqbal, 556 U.S. 662 (2009) (application of plausibility standard to constitutional claims)
Monell v. Department of Social Services, 436 U.S. 658 (1978) (municipal liability requires unconstitutional policy or custom)
Pembaur v. City of Cincinnati, 475 U.S. 469 (1986) (official-policy requirement and final policymaker concept)
West v. Atkins, 487 U.S. 42 (1988) (elements of § 1983 liability and state-action requirement)
Doe By & Through Doe v. Washington County, 150 F.3d 920 (8th Cir. 1998) (requirements to prove existence of a governmental custom)
Sanders v. Sears, Roebuck & Co., 984 F.2d 972 (8th Cir. 1993) (corporate § 1983 liability limited to its own unconstitutional policies)
Topchian v. JPMorgan Chase Bank, N.A., 760 F.3d 843 (8th Cir. 2014) (pro se complaints must give fair notice; liberal construction applies)
Ellis v. Norris, 179 F.3d 1078 (8th Cir. 1999) (personal involvement required for individual § 1983 liability)
Keeper v. King, 130 F.3d 1309 (8th Cir. 1997) (general supervisory responsibility insufficient for personal liability)
Royal v. Kautzky, 375 F.3d 720 (8th Cir. 2004) (PLRA bars recovery for mental or emotional injury absent physical injury)