Vanderpool v. Smoak (INMATE 2)
1:25-cv-00187
M.D. Ala.Jun 30, 2025Background
- Plaintiff Christopher Allen Vanderpool, an inmate at Houston County Jail, alleges constitutional violations connected to his work assignment and related grievance process.
- Plaintiff claims “discriminatory actions” occurred when he was not assigned to the inmate kitchen crew and alleges mishandling of his grievances about this issue.
- The alleged incidents occurred between December 13, 2024, and February 7, 2025.
- Vanderpool seeks injunctive relief, procedural changes at the Jail, and compensation for emotional distress.
- Defendant Jason Smoak moved for a more definite statement under Rule 12(e), arguing the Complaint was vague and failed to specify legal or factual bases for the claims.
- The court reviews whether the Complaint needs clarification to allow a proper response, particularly regarding Smoak's individual conduct or potential supervisory liability.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether the Complaint provides sufficient specificity of claims and factual basis | Vanderpool believes his rights were violated through discriminatory inmate work assignment decisions and mishandling of grievances | Smoak argues the Complaint is too vague and general, lacking specifics as to legal/factual bases and his personal involvement | Motion granted in part: Plaintiff must clarify how Defendant’s actions violated rights; otherwise denied |
| Whether the Complaint constitutes a prohibited “shotgun pleading” | No explicit argument but follows standard pro se form | Argues the Complaint is a shotgun pleading lacking coherence and specificity | Court finds Complaint does not meet the definition of a shotgun pleading |
| Whether Defendant is given adequate notice under Rule 8 to respond | Plaintiff’s filing gives factual background using a court-provided form | Defendant claims form’s lack of detail prevents him from formulating a defense or asserting proper defenses | Court finds only the lack of connection to Smoak himself warrants requiring clarification |
| Propriety of supervisory liability allegations | Alleges constitutional violation without specifying Smoak’s role | Points out no facts show Smoak’s personal involvement or causal connection | Court orders Plaintiff to specify Smoak’s involvement if supervisory liability is intended |
Key Cases Cited
- Bell Atl. Corp. v. Twombly, 550 U.S. 544 (2007) (pleading must give fair notice of the claim and its grounds)
- Douglas v. Yates, 535 F.3d 1316 (11th Cir. 2008) (complaint must specify defendant’s overt acts)
- Campbell v. Air Jamaica Ltd., 760 F.3d 1165 (11th Cir. 2014) (pro se pleadings receive less stringent standards, but must comply with rules)
- Weiland v. Palm Beach Cnty. Sheriff’s Office, 792 F.3d 1313 (11th Cir. 2015) (identifies categories of shotgun pleadings)
- Myrick v. Fulton Cnty., Ga., 69 F.4th 1277 (11th Cir. 2023) (supervisory liability requires personal participation or causal connection)