Watts 664661 v. Collins
1:25-cv-00243
W.D. Mich.Mar 11, 2025Background
- Plaintiff Justin Michael Watts, an inmate at Marquette Branch Prison, alleges civil rights violations under 42 U.S.C. § 1983 for events occurring at Carson City Correctional Facility.
- Plaintiff claims he was repeatedly harassed and threatened by Correctional Officer Collins, and his requests for protection and transfer to other facility units were ignored by supervisory staff.
- On December 18, 2023, Plaintiff alleges that Collins and Sgt. Schutt physically assaulted him, causing serious injury, after he sought mental health assistance.
- Plaintiff further alleges delayed and inadequate medical care from Defendant Wuest and an unidentified medical provider, asserting his serious post-assault injuries were not properly treated.
- The court reviewed the complaint under the Prison Litigation Reform Act (PLRA) for sufficiency before service to any defendants.
- The court dismissed claims against the "Unknown Medical Provider" and official-capacity claims, but allowed individual-capacity Eighth Amendment claims against Collins, Schutt, Rewerts, Mates, Garcia, Nevins, and Wuest to proceed.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Sufficiency of § 1983 claims vs. Unnamed Medical Provider | The provider is liable for not providing adequate care | No specific actions or policies alleged | Dismissed; insufficient pleading |
| Official capacity liability for damages | State officials/agency are liable in official capacity | MDOC not person under §1983; immunity | Dismissed; Eleventh Amendment bars |
| Eighth Amendment – Excessive force | Collins/Schutt used excessive force | Not presented at screening stage | Claims allowed to proceed |
| Eighth Amendment – Failure to protect | Supervisors ignored credible safety threats | Not presented at screening stage | Claims allowed to proceed |
| Eighth Amendment – Deliberate indifference | Delay/denial of medical care post-assault | Not presented at screening stage | Claims allowed to proceed |
Key Cases Cited
- Bell Atl. Corp. v. Twombly, 550 U.S. 544 (pleading standard for plausibility)
- Ashcroft v. Iqbal, 556 U.S. 662 (plausibility standard and pleading requirements)
- Haines v. Kerner, 404 U.S. 519 (liberal reading for pro se pleadings)
- Estelle v. Gamble, 429 U.S. 97 (deliberate indifference to medical needs under Eighth Amendment)
- Farmer v. Brennan, 511 U.S. 825 (deliberate indifference and failure to protect standard)
- Hudson v. McMillian, 503 U.S. 1 (Eighth Amendment excessive force standard)
- Will v. Mich. Dep’t of State Police, 491 U.S. 58 (states are not persons for the purposes of §1983)
- Kentucky v. Graham, 473 U.S. 159 (official capacity lawsuits as suits against the entity)
- Monell v. Dept. of Soc. Servs., 436 U.S. 658 (standards for municipal/corporate liability under §1983)