Robinson v. Scaturo
1:16-cv-02311
D.S.C.Jun 16, 2017Background
- Plaintiff Shawn Michael Robinson, proceeding pro se, brought a 42 U.S.C. § 1983 action against multiple state mental-health officials and related personnel alleging various constitutional violations.
- The case was referred to Magistrate Judge Shiva V. Hodges, who issued a Report and Recommendation addressing motions for summary judgment and dismissal by several defendants.
- Defendants filed: a collective motion for summary judgment, Dr. Amy Swan moved to dismiss, and Defendants John McGill and Allen Wilson moved to dismiss.
- Magistrate Judge Hodges recommended granting all pending dispositive motions (summary judgment and dismissals). The Report detailed facts and legal standards (incorporated by the district court).
- Plaintiff filed a one-page objection that did not identify specific errors in the Magistrate Judge’s analysis and instead referenced other pending cases and sought dismissal without prejudice pending their outcomes.
- The district court reviewed the record, found no specific objections warranting de novo review, concluded there was no clear error, overruled the objections, adopted the Report, and granted the defendants’ motions.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether summary judgment is proper on Plaintiff's § 1983 claims | Robinson asserted constitutional violations by numerous mental-health and prison officials | Defendants argued Plaintiff failed to establish facts creating a genuine dispute of material fact and are entitled to judgment as a matter of law | Granted: Court adopted Magistrate Judge's recommendation and entered summary judgment for defendants |
| Whether Dr. Amy Swan should be dismissed | Robinson challenged Swan’s actions in his complaint | Swan moved to dismiss for failure to state a claim and/or lack of viable legal theory | Granted: Swan’s motion to dismiss was granted |
| Whether Defendants McGill and Wilson should be dismissed | Robinson named McGill (state DMH director) and Wilson (Attorney General) among defendants | McGill and Wilson moved to dismiss (likely on grounds such as lack of personal involvement or legal insufficiency) | Granted: McGill and Wilson’s motion to dismiss was granted |
| Whether Plaintiff’s objections require de novo review of the Report | Robinson filed a brief, nonspecific objection referencing other cases and seeking dismissal without prejudice | Defendants relied on the Magistrate’s thorough Report and the rule that vague objections do not trigger de novo review | Overruled: Court found objections nonspecific, reviewed for clear error, found none, and adopted the Report |
Key Cases Cited
- Mathews v. Weber, 423 U.S. 261 (1976) (magistrate judge’s report is a recommendation; district court makes final determination)
- Orpiano v. Johnson, 687 F.2d 44 (4th Cir. 1982) (general or conclusory objections do not require de novo review)
- Diamond v. Colonial Life & Accident Ins. Co., 416 F.3d 310 (4th Cir. 2005) (in absence of timely specific objection, magistrate judge’s conclusions reviewed for clear error)