SAUNDERS v. C.C.C.F., 1:16-cv-09534

Background

Plaintiff Andre Saunders, proceeding in forma pauperis, sued under 42 U.S.C. § 1983 alleging unconstitutional conditions of confinement at Camden County Jail for incidents between 2010 and 2016.
Original complaint alleged overcrowding and a leaking toilet; Amended Complaint added allegations of sleeping four inmates in a two-person cell, cold food served near a filthy toilet, poor ventilation aggravating asthma, an infection (a boil), unvetted inmate food servers, and resulting depression.
The District Court screened the original complaint under 28 U.S.C. § 1915(e)(2)(B), dismissed claims against the facility with prejudice (facility is not a “person” under § 1983) and dismissed conditions claims without prejudice for failure to plead facts showing a constitutional violation, granting leave to amend.
The Amended Complaint named specific jail officials (Warden Owens, Capt. Taylor, Class Dept. L. Kareem, Medical Sup. C. Martinelli, and others) but failed to allege their personal involvement in any constitutional violation.
The court applied due process and Eighth/Fourteenth Amendment standards for conditions claims and concluded the facts pleaded (cold food, poor ventilation, overcrowding, a boil) were insufficient to show conditions so egregious as to violate constitutional rights.
Because Plaintiff had already been granted leave to amend and again failed to cure pleading defects, the court dismissed all claims in both the original and amended complaints with prejudice as futile.

Issues

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether Camden County Jail is a proper § 1983 defendant	Saunders sued the jail as the liable entity for conditions	Jail (and court) contend a correctional facility is not a “person” under § 1983	Dismissed with prejudice: facility not a § 1983 person
Whether named officials can be held liable without pleaded personal involvement	Saunders named Warden and other officials as defendants	Defendants argue complaint lacks allegations of their personal actions; respondeat superior is insufficient	Dismissed without prejudice initially, then with prejudice after amendment: no personal involvement alleged
Whether the conditions alleged state a due process/Eighth Amendment violation	Saunders alleges overcrowding, unsanitary toilet, cold food, poor ventilation, a boil, and mental effects	Defendants argue allegations are insufficiently severe or prolonged to meet constitutional threshold	Dismissed: allegations do not plausibly show conditions that are a constitutional violation
Whether further amendment should be allowed	Saunders was previously granted leave to amend to provide facts	Court notes prior opportunity and failure to cure pleading defects	Dismissed with prejudice as further amendment would be futile

Key Cases Cited

Carver v. Foerster, 102 F.3d 96 (3d Cir. 1996) (defines “persons” acting under color of state law for § 1983)
Hafer v. Melo, 502 U.S. 21 (1991) (officials sued in individual capacity act under color of state law)
West v. Atkins, 487 U.S. 42 (1988) (state-law authority can supply action under color of state law)
Monell v. N.Y.C. Dep't of Social Services, 436 U.S. 658 (1978) (municipalities and local government units are "persons" under § 1983)
Rode v. Dellarciprete, 845 F.2d 1195 (3d Cir. 1988) (personal involvement required for § 1983 liability; respondeat superior insufficient)
Ashcroft v. Iqbal, 556 U.S. 662 (2009) (plaintiff must plead each official’s own unconstitutional conduct)
Rhodes v. Chapman, 452 U.S. 337 (1981) (‘‘the Constitution does not mandate comfortable prisons’’; conditions must be sufficiently extreme)
Hubbard v. Taylor, 538 F.3d 229 (3d Cir. 2008) (totality-of-conditions test for pretrial detainee due process claims)
City of Sacramento v. Lewis, 523 U.S. 833 (1998) (only most egregious official conduct shocks the conscience)