SANDERS v. CAMDEN COUNTY CORRECTIONAL FACILITY, 1:16-cv-07912

Pro se plaintiff Rocmon L. Sanders sued Camden County Correctional Facility (CCCF), Warden David Owens, and Camden County Board of Chosen Freeholders under 42 U.S.C. § 1983 for allegedly unconstitutional conditions of confinement and an officer "assault" in 2005.
Plaintiff alleged long-term overcrowding, unsanitary conditions, sleeping on a thin mattress on a concrete floor, contracting scabies (treated in 2001), and occasional physical assaults (including by an officer in 2005).
Plaintiff sought compensatory and punitive damages and injunctive relief (a pre-screening process and remedial procedures for overcrowding).
The Court screened the in forma pauperis complaint under 28 U.S.C. § 1915(e)(2).
The Court dismissed claims against CCCF with prejudice because a correctional facility is not a “person” under § 1983, and dismissed the 2005 excessive-force/assault claim with prejudice as time-barred by New Jersey’s two-year statute of limitations.
The Court allowed conditions-of-confinement claims to proceed against Owens and the County Board only for confinements from which Sanders was released after October 5, 2014; injunctive relief was dismissed as moot because plaintiff is no longer confined at CCCF.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether CCCF is a proper § 1983 defendant	Sanders sued CCCF for damages for unconstitutional conditions	CCCF is not a “person” under § 1983 and cannot be sued	Dismissed with prejudice: correctional facility is not a § 1983 person
Whether the 2005 officer "assault" claim is timely	Sanders alleges excessive force/assault in 2005	Defendants assert statute of limitations bars the claim	Dismissed with prejudice as time-barred (NJ two-year period)
Whether conditions-of-confinement allegations state a § 1983 claim against Owens and BOF	Sanders alleges long-term overcrowding, unsanitary conditions, injuries (scabies, back pain), and policy failures by Owens/BOF	Defendants challenge sufficiency and timeliness of claims predating limitations cutoff	Allowed to proceed as to confinements ending after Oct 5, 2014; earlier claims barred by statute of limitations
Whether injunctive relief is available	Sanders seeks injunctive reforms at CCCF	Defendants note Sanders is no longer confined, and a class action addresses injunctive relief	Injunctive relief dismissed as moot for Sanders; class action may address systemic relief

Groman v. Township of Manalapan, 47 F.3d 628 (3d Cir. 1995) (elements required to state a § 1983 claim)
Gomez v. Toledo, 446 U.S. 635 (1980) (state-action and § 1983 principles)
Hafer v. Melo, 502 U.S. 21 (1991) (who qualifies as a “person” under § 1983 and official/state-capacity distinctions)
West v. Atkins, 487 U.S. 42 (1988) (acting under color of state law standard)
Monell v. N.Y.C. Dep’t of Social Servs., 436 U.S. 658 (1978) (municipal liability and policy/custom requirement)
Bell v. Wolfish, 441 U.S. 520 (1979) (pretrial detainee treatment: determining punishment vs. legitimate government purpose)
Wilson v. Garcia, 471 U.S. 261 (1985) (statute of limitations governs § 1983 actions using state personal-injury limitations)
Dique v. N.J. State Police, 603 F.3d 181 (3d Cir. 2010) (application of state limitations to § 1983 claims)
Montanez v. Secretary, Pa. Dep’t of Corr., 773 F.3d 472 (3d Cir. 2014) (accrual rule: cause of action accrues when plaintiff knew or should have known of injury)
Fowler v. UPMC Shadyside, 578 F.3d 203 (3d Cir. 2009) (plausibility standard for pleadings)
Ashcroft v. Iqbal, 556 U.S. 662 (2009) (labels-and-conclusions insufficient to plead plausible claim)
Bell Atlantic Corp. v. Twombly, 550 U.S. 544 (2007) (Twombly plausibility standard for pleadings)