Smith v. Helder, 5:17-cv-05164

Background

Plaintiff Leon Michael Smith, a jail detainee, sued under 42 U.S.C. § 1983 alleging multiple constitutional violations arising from his July 9–16, 2017 stay at Washington County Detention Center.
Material factual allegations: denial of a blanket (3 days), forced to use a hair chemical over his body causing a skin reaction, placement on knees and threatened with a Taser under a knife mural, lack of an intercom/button in his cell, delayed response to seizures and panic attacks, withheld mental-health medication, placement in maximum-security pod then assaulted when his door was opened, and later put in a restraint chair after he complained.
Smith named Sheriff Tim Helder, Major Randall Denzer, Deputies Cervantes, Howerton, Taylor, Bookout, Atchley, Wingate, Minor, Hill, Ruff, and Smith.
The court screened the complaint under 28 U.S.C. § 1915A and dismissed several claims/defendants without prejudice for failure to state a claim.
The court permitted to proceed: (1) a threatened-use-of-Taser claim against Deputies Cervantes and Howerton; and (2) a retaliation claim against Deputies Hill, Ruff, and Smith. All other claims and the listed defendants were dismissed without prejudice.

Issues

Issue	Plaintiff's Argument	Defendant's Argument	Held
Conditions of confinement (blanket, hygiene, hour out, forced chemical)	Smith: short-term deprivations and forced chemical caused harm and constitutional injury	Defendants: deprivations were minimal/temporary and lacked deliberate indifference	Dismissed — allegations insufficient to show substantial risk of serious harm or deliberate indifference
Threatened use of Taser	Smith: Cervantes/Howerton placed a Taser at his head/back while handcuffed and on knees, with a red beam, creating credible threat	Defendants: conduct was verbal/harassing, not a constitutional violation	Allowed to proceed — court found a plausible claim based on credible threat of immediate harm
Denial of medical care (seizures, delayed response, withheld meds)	Smith: had seizures/panic attacks, no intercom, deputies slow to respond, meds withheld	Defendants: no specific acts pled against named defendants; no showing of deliberate indifference by them	Dismissed — plaintiff failed to allege personal involvement or deliberate indifference by named defendants
Failure to protect from inmate attack	Smith: Deputy Taylor opened cell early and deputies were slow/failed to use equipment, resulting in assault	Defendants: incident alone insufficient; no facts showing officials knew and disregarded substantial risk	Dismissed — allegations do not plausibly show awareness and deliberate disregard of excessive risk
Retaliation for grievances (restraint chair)	Smith: placed in strap-down chair after complaining about lack of intercom, in retaliation	Defendants: conduct not actionable or not linked to grievance	Allowed to proceed — court found a plausible First Amendment retaliation claim
Official‑capacity / supervisory liability	Smith: sued Sheriff Helder and Major Denzer in official capacity and supervisory roles	Defendants: no policy/custom alleged; supervisors not liable on respondeat superior theory	Dismissed — no Monell claim or personal involvement alleged

Key Cases Cited

Neitzke v. Williams, 490 U.S. 319 (frivolousness standard for pro se in forma pauperis suits)
Bell Atlantic Corp. v. Twombly, 550 U.S. 544 (plausibility standard for pleading)
Farmer v. Brennan, 511 U.S. 825 (deliberate indifference standard for conditions of confinement/failure to protect)
Rhodes v. Chapman, 452 U.S. 337 (Eighth Amendment conditions of confinement principles)
Hudson v. McMillian, 503 U.S. 1 (objective harm standard for Eighth Amendment excessive force/conditions claims)
Monell v. Department of Social Services, 436 U.S. 658 (municipal liability requires policy or custom)
Burton v. Livingston, 791 F.2d 97 (threats with a weapon can state a constitutional claim when credible)
Ashcroft v. Iqbal, 556 U.S. 662 (personal involvement and plausibility in § 1983 supervisory claims)