Stone v. Duffield Jail-Medical
7:17-cv-00101
W.D. Va.Jul 10, 2017Background
- Plaintiff Timothy Stone, a pro se Virginia inmate, sued under 42 U.S.C. § 1983 alleging Duffield Jail medical staff refused to authorize him for a jail job to earn money toward fines and that officers threatened him to drop the suit.
- Stone initially named “Duffield Jail-Medical” and Captain Parks; court instructed him to amend to name proper individual defendants but he did not file a formal amended complaint.
- Stone later sought to add Officer Scott, Officer Davis, and Nurse Scott as defendants and asked for transfer, monetary damages, and early release; he was transferred to another SVRJA facility during the litigation.
- Stone alleged Nurse Scott refused to explain medical ineligibility for work; he alleged two inmates threatened him after an Officer Scott remark and Officer Davis stood by smiling.
- Court found Duffield Jail-Medical is not a suable “person,” found no facts showing Captain Parks’s personal involvement, concluded there is no constitutional right to jail employment, and held Stone’s early-release request improperly sought via § 1983.
- Court dismissed claims against Officers Scott and Davis for failure to exhaust administrative remedies, and dismissed the complaint without prejudice under 28 U.S.C. § 1915A(b)(1).
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether “Duffield Jail-Medical” and Captain Parks are proper § 1983 defendants | Stone treats jail medical staff and Captain Parks as defendants responsible for denying job and failing to respond | Medical staff as a group is not a legal person; Parks not shown to have personally acted or been deliberately indifferent | Dismissed: jail medical (not a person) and Parks (no personal involvement) |
| Whether denial of jail job violated § 1983 | Stone: denial of job prevented earning money for fines and caused distress | Defendants: no constitutional right to work in jail | Dismissed: prisoners have no constitutionally protected right to work |
| Whether § 1983 can seek early release | Stone seeks transfer/early release as relief | Defendants: habeas, not § 1983, is proper vehicle for attacking duration or fact of confinement | Dismissed: claims for early release not cognizable under § 1983 (Preiser) |
| Whether claims about threats by officers exhausted administrative remedies | Stone raised threats to court before using jail grievance appeals | Defendants: plaintiff failed to exhaust available administrative remedies before suing | Dismissed: claims against Officers Scott and Davis barred for failure to exhaust under 42 U.S.C. § 1997e(a) |
Key Cases Cited
- Giarratano v. Johnson, 521 F.3d 298 (4th Cir. 2008) (pleading standard for dismissal under § 1915A and Twombly/Iqbal framework)
- Bell Atl. Corp. v. Twombly, 550 U.S. 544 (2007) (facial plausibility standard for pleadings)
- Ashcroft v. Iqbal, 556 U.S. 662 (2009) (individualized pleading requirement for government officials)
- Cooper v. Sheehan, 735 F.3d 153 (4th Cir. 2013) (§ 1983 suits against medical staff and requirement that defendant be a person)
- Slakan v. Porter, 737 F.2d 368 (4th Cir. 1984) (supervisory liability requires knowledge and deliberate indifference plus causal link)
- Preiser v. Rodriguez, 411 U.S. 475 (1973) (habeas is proper remedy for challenges to fact or duration of confinement)
- Custis v. Davis, 851 F.3d 358 (4th Cir. 2017) (courts may sua sponte dismiss for failure to exhaust administrative remedies)