REDDICK v. HICKS, 3:22-cv-06926

Plaintiff Jaquan Reddick alleges he contracted COVID-19 while incarcerated at Mercer County Correctional Center in May 2020 and claims defendants failed to follow CDC guidance, train staff, implement policies, and provide adequate medical care.
Defendants named include County of Mercer, MCCC, Mercer County Sheriff’s Office, New Jersey Department of Corrections (NJDOC), former NJDOC Commissioner Marcus O. Hicks, the MCCC warden, several John/Jane Doe individuals and unspecified corporations.
Reddick filed in New Jersey Superior Court on April 29, 2022; defendants removed to federal court on December 1, 2022; State Defendants moved to dismiss on December 29, 2022; County Defendants joined in part.
The State Defendants argued (among other points) that NJDOC and Hicks in his official capacity are not “persons” under 42 U.S.C. § 1983 or the New Jersey Civil Rights Act (NJCRA); the County Defendants argued the complaint engages in impermissible group pleading.
The court granted in part and denied in part: it dismissed with prejudice the claims against NJDOC and Hicks in his official capacity (not “persons” under § 1983/NJCRA) and dismissed the remainder of the complaint without prejudice for improper group pleading under Rule 8; other defenses were denied without prejudice as moot. Judgment entered July 18, 2023.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether NJDOC and Hicks (official capacity) are “persons” under § 1983 and the NJCRA	Reddick sued NJDOC and Hicks under § 1983/NJCRA for constitutional violations tied to COVID-19 conditions	NJDOC and Hicks (official capacity) are arms of the State and thus not “persons” under § 1983 or the NJCRA	Court: Dismissed claims against NJDOC and Hicks (official capacity) with prejudice — not “persons”
Whether the complaint engages in impermissible group pleading under Rule 8	Reddick alleges systemic failures by defendants (policies, training, medical care)	Complaint lumped many defendants together without specifying who did what	Court: Dismissed remainder of complaint without prejudice for failing to identify discrete acts by discrete defendants
Whether the complaint adequately pleads State Defendants’ personal involvement	Reddick alleges failures attributable to institutional actors	Defendants argued facts insufficient for personal involvement (and raised non-person defense)	Court treated argument as non-person issue and dismissed NJDOC/Hicks; did not reach personal-involvement merits
Whether defendants’ other defenses (e.g., qualified immunity, merits) defeat the complaint	Reddick seeks damages for constitutional violations	Defendants raised qualified immunity and additional factual/pleading defenses	Court: Declined to rule on remaining defenses — denied without prejudice as moot given other dismissals

Phillips v. County of Allegheny, 515 F.3d 224 (3d Cir. 2008) (accept factual allegations as true at motion-to-dismiss stage)
Bell Atl. Corp. v. Twombly, 550 U.S. 544 (2007) (pleading must provide factual grounds, not mere labels)
Papasan v. Allain, 478 U.S. 265 (1986) (courts need not accept legal conclusions as factual allegations)
Ashcroft v. Iqbal, 556 U.S. 662 (2009) (plausibility standard for pleading)
Will v. Mich. Dep’t of State Police, 491 U.S. 58 (1989) (states and officials sued in official capacity are not “persons” under § 1983)
Estate of Lagano v. Bergen County Prosecutor’s Office, 769 F.3d 850 (3d Cir. 2014) (NJCRA construed like § 1983 re: definition of “person”)
Garrett v. Wexford Health, 938 F.3d 69 (3d Cir. 2019) (pleading must identify discrete defendants and actions)
Travaline v. U.S. Supreme Court, [citation="424 F. App'x 78"] (3d Cir. 2011) (Rule 8 requires a short and plain statement of entitlement to relief)