Ordonez v. Mental Health Treatment Center, 1:20-cv-00927

Pro se plaintiff Jeremiah Ordoñez, an inmate at Central New Mexico Correctional Facility’s Mental Health Treatment Center (MHTC), alleges he was detained in a psych ward, forced to take psychotropic medication, and suffered slowed cognitive functioning.
He named MHTC, “Doctor Fnu Suar,” and unidentified “Staff” as defendants, seeking injunctive relief (proper care/housing) and damages.
Procedural history: initial handwritten letter (Sept. 2020) led to a cure order; IFP status granted; plaintiff filed a formal Complaint on Nov. 15, 2022.
The Court screened the Complaint under 28 U.S.C. § 1915A and Fed. R. Civ. P. 12(b)(6).
The Court found the Complaint failed to (1) identify the “Staff” defendants adequately, (2) plead facts establishing defendants acted under color of state law/§ 1983 liability, and (3) allege the objective and subjective elements required for an Eighth Amendment deliberate-indifference claim.
Result: Complaint dismissed without prejudice; Ordoñez given 30 days to file an amended complaint or risk dismissal with prejudice.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Adequate identification of "Staff" defendants	Ordoñez names "Staff" collectively as defendants	No responsive pleadings; Court reviewed sufficiency	Dismissed claims against unnamed "Staff" without prejudice for inadequate identification
§ 1983/state-action pleading	Ordoñez alleges constitutional harms from MHTC treatment	No factual allegations tying individual defendants to state action	Dismissed § 1983 claims for failure to plead who did what and whether defendants are state actors
Eighth Amendment deliberate indifference	Forced psychotropics caused cognitive harm; amounts to cruel and unusual punishment	Court: allegations show disagreement with treatment but not objective/subjective elements	Dismissed Eighth Amendment claims without prejudice for failing to allege a serious medical need and deliberate indifference
Amendment / disposition	Requests relief and damages; seeks court to address rights	N/A — Court applied screening standards under § 1915A / Rule 12(b)(6)	Complaint dismissed without prejudice; plaintiff may amend within 30 days or face possible dismissal with prejudice

Hall v. Bellmon, 935 F.2d 1106 (10th Cir. 1991) (pro se pleadings construed liberally but must meet Rule 8)
Ashcroft v. Iqbal, 556 U.S. 662 (2009) (pleading standards—conclusory allegations insufficient)
Bell Atl. Corp. v. Twombly, 550 U.S. 544 (2007) (plausibility standard for complaints)
Robbins v. Oklahoma, 519 F.3d 1242 (10th Cir. 2008) (complaint must state exactly who did what to whom)
28 U.S.C. § 1915A (statutory screening authority cited by court)
Estelle v. Gamble, 429 U.S. 97 (1976) (deliberate indifference to serious medical needs violates the Eighth Amendment)
Farmer v. Brennan, 511 U.S. 825 (1994) (objective and subjective components of deliberate indifference)
Polk County v. Dodson, 454 U.S. 312 (1981) (conduct must be under color of state law for § 1983 liability)
Lugar v. Edmonson Oil Co., 457 U.S. 922 (1982) (state-action tests and when private conduct is attributable to the State)
Johnson v. Rodrigues, 293 F.3d 1196 (10th Cir. 2002) (articulates tests for when non-state actors’ conduct is fairly attributable to the State)
Roper v. Grayson, 81 F.3d 124 (10th Cir. 1996) (permitting unnamed defendants when sufficiently described)
Self v. Crum, 439 F.3d 1227 (10th Cir. 2006) (discussing objective/subjective elements for Eighth Amendment medical claims)