Watson-Kaufman v. Department of Corrections Virginia
7:24-cv-00714
| W.D. Va. | Jun 30, 2025Background
- Brandon Watson-Kaufman, a Virginia inmate proceeding pro se, filed a civil rights action under 42 U.S.C. § 1983.
- The defendants named are the Virginia Department of Corrections (VDOC) and Beasley, identified as Unit Manager/Warden.
- The complaint fails to allege any specific actions by Beasley or any other individual, nor does it allege specific constitutional rights violations.
- The complaint lists the Department of Corrections, a state entity, which is not considered a "person" under § 1983 and is immune from suit per the Eleventh Amendment.
- The court has given Watson-Kaufman 30 days to amend his complaint to address these deficiencies or face dismissal for failure to state a claim.
- The court provided the plaintiff with instructions and a form to properly file an amended complaint.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether the Department of Corrections can be sued under § 1983 | VDOC violated rights | VDOC is not a "person" under § 1983 and is immune under 11th Amendment | Dismissed as improper defendant |
| Whether the complaint states a valid claim against Beasley | Beasley is liable as listed in caption | Complaint does not allege Beasley's actions or personal involvement | Dismissed for failure to state claim, with leave to amend |
| Requirement of alleging individual involvement in constitutional violation | Plaintiff claims rights violated by prison officials | Argued complaint fails to state specific unlawful acts by any individual | Plaintiff must amend to state individual acts and specific violations |
| Opportunity to amend complaint | Plaintiff seeks relief for alleged rights violations | N/A | Plaintiff given 30 days to amend complaint or case will be dismissed |
Key Cases Cited
- Loftus v. Bobzien, 848 F.3d 278 (4th Cir. 2017) (clarifying liability under § 1983 is personal and requires violation by a "person")
- Trulock v. Freeh, 275 F.3d 391 (4th Cir. 2001) (personal involvement necessary to state a claim under § 1983)
- Wilcox v. Brown, 877 F.3d 161 (4th Cir. 2017) (a complaint must contain factual details of a defendant’s involvement)
- Fauconier v. Clarke, 966 F.3d 265 (4th Cir. 2020) (state departments are not "persons" under § 1983 and are immune from suit)