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Robinson v. AT Wall
1:12-cv-00319
| D.R.I. | Dec 12, 2012
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Background

  • Robinson, a Connecticut state prisoner, was transferred to RIDOC’s Adult Correctional Institutions (ACI) in Cranston, RI and filed a pro se civil rights complaint under 42 U.S.C. §1983 with in forma pauperis and a service request.
  • The court screened the complaint under 28 U.S.C. §§1915(e)(2) and 1915A and concluded it failed to state a claim on which relief may be granted, warranting dismissal.
  • Robinson alleged that on April 30, 2009 a nurse at the Intake Service Center forcibly drew his blood for an HIV test and that he was denied a grievance about the procedure.
  • He sought compensation for the forced HIV test and related pain, and cited a related Connecticut case (Petaway) as support; the court scrutinized and rejected reliance on that precedent.
  • The court ultimately dismissed all defendants except Nurse Jane Doe, and found no plausible constitutional claim based on the presented facts, leading to dismissal of the entire complaint and denial of in forma pauperis and service requests as moot.

Issues

Issue Plaintiff's Argument Defendant's Argument Held
Whether Robinson states a plausible §1983 claim against the named defendants. Robinson argues his forced HIV testing violated federal rights and seeks damages. Defendants contend the claim is not viable given controlling state law and lack of proper support in precedent. Claims against other defendants dismissed; no plausible federal claim stated.
Whether Robinson had a right to refuse HIV testing and if its denial would violate his rights. Robinson contends he should have a right to refuse HIV testing. Rhode Island law and the Compact authorize testing without consent in this context. There is no constitutional right to refuse under the cited framework; testing without consent is permissible.
Whether Petaway v. DiNitto controls and forecloses Robinson’s claim. Robinson relies on Petaway as support for compensation and rights assertion. Petaway is distinguishable and does not create a plausible claim in this case. Petaway cited but does not salvage a plausible federal claim; complaint dismissed.

Key Cases Cited

  • Ashcroft v. Iqbal, 556 U.S. 662 (U.S. 2009) (pleading standard: plausibility required for claims)
  • Bell Atl. Corp. v. Twombly, 550 U.S. 544 (U.S. 2007) (pleading standard requiring plausible facts)
  • Estelle v. Gamble, 429 U.S. 97 (U.S. 1976) (deliberate indifference standard for medical care claims)
  • Greater Providence MRI Ltd. P’Ship v. Medical Imaging Network of S. New England, Inc., 32 F. Supp. 2d 491 (D.R.I. 1998) (court’s approach to screening and pleading standards)
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Case Details

Case Name: Robinson v. AT Wall
Court Name: District Court, D. Rhode Island
Date Published: Dec 12, 2012
Docket Number: 1:12-cv-00319
Court Abbreviation: D.R.I.