Rivera-Diaz v. Administracion de Correccion
3:16-cv-01176
| D.P.R. | Oct 14, 2016Background
- Miguel Rivera Díaz, proceeding pro se, filed an amended §1983-style complaint alleging constitutional violations (mail withholding, medical notification delay, and other misconduct) while incarcerated.
- Plaintiff originally named Orlando Rivera Garcia in the first complaint (in Spanish) but omitted him from the English-language amended complaint.
- The Puerto Rico Department of Corrections and Rehabilitation (PRDCR) and several individual correctional staff/supervisors were named in the amended complaint; none of the seven individuals had been served.
- Rivera Garcia moved to dismiss; PRDCR also moved to dismiss.
- The district court reviewed Eleventh Amendment immunity, Rule 12(b)(6) plausibility standards (Twombly/Iqbal), and the minimal pleading requirements of Rule 8(a), applied a lenient standard for a pro se plaintiff, and considered sua sponte dismissal principles.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether Rivera Garcia remains a defendant | Rivera named Rivera Garcia in original complaint alleging mail withholding | Rivera Garcia moved to dismiss | Rivera Garcia was not named in the amended complaint; motion granted — he is no longer a defendant |
| Whether PRDCR is subject to suit in federal court | Plaintiff sues PRDCR for constitutional violations | PRDCR asserts Eleventh Amendment sovereign immunity | PRDCR immune; claims dismissed with prejudice |
| Whether amended complaint meets Rule 8(a) pleading requirements | Plaintiff alleges wrongdoing by various staff but provides sparse facts | Defendants argue the complaint is conclusory and fails to state plausible claims | Complaint fails Rule 8(a) and plausibility standards; claims against seven individuals dismissed without prejudice |
| Whether sua sponte dismissal is appropriate | Implicitly seeks adjudication on the merits | Court cautions sua sponte dismissal is strong medicine but may be used if amendment would be futile | Court applies sua sponte dismissal (without prejudice) as appropriate for the individuals given pleading defects |
Key Cases Cited
- Connectu LLC v. Zuckerberg, 522 F.3d 82 (1st Cir. 2008) (an amended complaint ordinarily supersedes and replaces earlier complaints)
- Sossamon v. Texas, 563 U.S. 277 (2011) (overview of Eleventh Amendment immunity principles)
- Atascadero State Hospital v. Scanlon, 473 U.S. 234 (1985) (state immunity may be waived or abrogated only in limited circumstances)
- Seminole Tribe v. Florida, 517 U.S. 44 (1996) (limits on congressional abrogation of state sovereign immunity)
- Wilson v. Brown, 889 F.2d 1195 (1st Cir. 1989) (state penal systems are integral parts of the state for Eleventh Amendment purposes)
- Cooper v. Charter Communications Entertainments I, LLC, 760 F.3d 103 (1st Cir. 2014) (plausibility standard discussion applying Twombly/Iqbal)
- Ashcroft v. Iqbal, 556 U.S. 662 (2009) (legal conclusions are not entitled to an assumption of truth)
- Bell Atlantic Corp. v. Twombly, 550 U.S. 544 (2007) (plausibility pleading standard)
- Ocasio-Hernández v. Fortuño-Burset, 640 F.3d 1 (1st Cir. 2011) (disregard conclusory allegations and threadbare recitals when assessing plausibility)