Nashoanak v. Angol, 3:24-cv-00269

Jonathan Nashoanak, a pretrial detainee at Goose Creek Correctional Center, filed a civil rights complaint against correctional staff and an inmate, alleging failure to protect him from repeat sexual assault and harassment by another prisoner.
Named defendants include Superintendent Angol, Lieutenant Hermon, Sergeant Kirk, Correction Officer Mitchell, and the alleged assailant, prisoner Ronald Clayton.
Plaintiff asserts constitutional claims under the Fourteenth Amendment—failure to protect, unsafe conditions, and violation of equal protection—as well as state law tort claims (assault, battery, intentional infliction of emotional distress).
The court screened the complaint under 28 U.S.C. §§ 1915(e) and 1915A, which require dismissal for failure to state a claim or for frivolous/malicious cases, but also require leaving to amend unless amendment would be futile.
The court found the complaint deficient under Rule 8 (not providing a short, plain statement showing plausible entitlement to relief and failing to specify how each defendant is liable) and dismissed the complaint with leave to amend within 60 days.
The court advised plaintiff on correcting deficiencies and outlined standards for stating plausible Section 1983 and state law claims; some claims against certain defendants (e.g., Eighth Amendment, § 1983 claims against inmates) were dismissed with prejudice.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Failure to protect (14th Am.)	DOC staff failed to protect from known risk of inmate assault	Not specified (screening order at pleading stage)	Complaint fails Rule 8; no plausible claim as pleaded; leave to amend
Equal Protection (14th Am.)	Actions were arbitrary and discriminatory	Not specified	No facts pled showing discrimination based on protected class; dismissed, leave to amend
State law torts (assault, battery, IIED)	Clayton assaulted/harmed plaintiff; others caused emotional distress	Not specified	No jurisdiction unless federal claim is plausible; leave to amend IIED, tort claims must be restated if federal claims proceed
Supervisory liability	Angol liable for staff misconduct and failure to train	Not specified	No personal involvement or policy causally linked to harm; dismissed, leave to amend if facts exist

Bell v. Wolfish, 441 U.S. 520 (pretrial detainees have due process right against punitive jail conditions)
West v. Atkins, 487 U.S. 42 (Section 1983 requires state action)
Ashcroft v. Iqbal, 556 U.S. 662 (pleading standard: plausible claims needed, not mere conclusions)
Castro v. County of Los Angeles, 833 F.3d 1060 (sets elements of failure to protect claim for pretrial detainees)
Swierkiewicz v. Sorema N.A., 534 U.S. 506 (pleading must give defendant fair notice of claims)