Templin v. Does, 4:22-cv-00564

Plaintiff Joseph Templin, a pretrial detainee at Stone County Detention Center, filed a pro se § 1983 action and was granted IFP; the Court screened the complaint under the PLRA and allowed amendment.
Templin has a mechanical heart valve and alleges anticoagulation mismanagement: Coumadin was discontinued on July 5, 2022, his PT/INR levels were nontherapeutic, and he now receives only painful Lovenox injections.
He alleges the jail failed to follow up on a June 30, 2022 cardiology echocardiogram appointment, did not hospitalize or properly medicate him, and failed to honor a cardiac diet; he also complains of filthy conditions and black mold.
Defendants named in their personal capacities: Sheriff Lance Bonds, Administrator Robert Guilbert, Assistant Administrator Mary Kathrine, and nurse practitioner Lily Roberts (Boston Mountain Regional Health Clinic).
The magistrate judge found the Second Amended Complaint failed to state a claim: Roberts is a private actor with no alleged joint state action; Bonds, Guilbert, and Kathrine lacked individualized factual allegations; recommended dismissal without prejudice and that the dismissal count as a strike under 28 U.S.C. § 1915(g).

Issue	Plaintiff's Argument	Defendant's Argument	Held
State-action for § 1983 against NP Roberts	Roberts (clinic practitioner) provided medical care and discontinued Coumadin causing risk	Roberts is a private actor; no allegation she was a willful participant in joint activity with the state	Dismissed as to Roberts for failure to plead state action
Supervisory liability of Bonds, Guilbert, Mary Kathrine	Jail leaders responsible for jail policies/failures and staff treatment of Templin	No specific factual allegations showing each defendant’s personal involvement; vicarious liability not permitted	Dismissed for failure to plead individualized conduct against them
Eighth/Fourteenth Amendment deliberate indifference to serious medical need	Alleged nontherapeutic INR, stopped anticoagulant, missed follow-up, need for hospitalization	Allegations did not sufficiently connect named defendants (or show state action re: Roberts) to deliberate indifference	Dismissed for failure to state a plausible § 1983 medical-care claim
Dismissal and 1915(g) strike / IFP appeal good-faith certification	Seeks damages; alleges ongoing risk of stroke (imminent danger claimed implicitly)	Magistrate recommends dismissal and treating it as a strike; certifies IFP appeal would not be in good faith	Recommended dismissal without prejudice, recommended count as a § 1915(g) strike, and IFP appeal not in good faith

Neitzke v. Williams, 490 U.S. 319 (1989) (frivolous-action standard)
Bell Atl. Corp. v. Twombly, 550 U.S. 544 (2007) (plausibility pleading standard)
Ashcroft v. Iqbal, 556 U.S. 662 (2009) (requirement to plead each government-official’s own conduct)
Parrish v. Ball, 594 F.3d 993 (8th Cir. 2010) (no vicarious liability under § 1983; need individual actions)
Magee v. Trustees of Hamline Univ., 747 F.3d 532 (8th Cir. 2014) (private actor subject to § 1983 only if willful participant in joint state activity)
Pendleton v. St. Louis Cnty., 178 F.3d 1007 (8th Cir. 1999) (meeting-of-the-minds test for joint state action)
Madewell v. Roberts, 909 F.2d 1203 (8th Cir. 1990) (causal link and direct responsibility required for § 1983 liability)
Haines v. Kerner, 404 U.S. 519 (1972) (liberal construction of pro se complaints)
Denton v. Hernandez, 504 U.S. 25 (1992) (court may dismiss implausible or baseless allegations)
Gonzalez v. United States, 23 F.4th 788 (8th Cir. 2022) (discussion of counting prior dismissals as § 1915(g) strikes)