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Jackson v. Correctional Officer Schaff

United States District Court, E.D. Michigan, Southern Division

April 6, 2017




         I. Introduction

         This matter recently came before the Court on plaintiff Tenisha Jackson's pro se civil rights complaint under 42 U.S.C. § 1983. Plaintiff is an inmate at the Women's Huron Valley Correctional Facility in Ypsilanti, Michigan, and defendant Schaff is a correctional officer at the facility.

         The complaint alleges that, on March 2, 2016, an officer escorted Plaintiff along a walkway from one observation cell to another observation cell. The officer called for assistance when Plaintiff stopped walking and began talking to another prisoner on the walkway. Defendant Schaff answered the call for help. He grabbed Plaintiff's arms, which were handcuffed behind her back, and lifted her arms toward the back of her head. According to Plaintiff, this conduct caused her a great deal of pain, embarrassment, and humiliation. Furthermore, when she and Defendant reached their destination, Defendant attempted to throw her into the observation room because she was not responding quickly enough to his order to enter the room. During the ensuing altercation, Defendant grabbed Plaintiff's buttock and breast.

         Plaintiff alleges that the officers rushed her because it was near the end of their shift and because she was not walking or responding as quickly as the officers would have liked. She maintains that the officers did not have to put their hands on her and subject her to improper and painful touching, manhandling, and abuse. She also claims that Defendant's conduct constituted cruel and unusual punishment, and even though her body no longer bears the marks of the altercation, she remains emotionally traumatized by the experience and repulsed by Defendant's brutality. She seeks money damages and a declaratory judgment stating that Defendant's conduct violated her rights under the Eighth and Fourteenth Amendments to the United States Constitution.

         II. Legal Framework

         The Court granted Plaintiff's application to proceed without prepaying the fees and costs for this action. See ECF No. 3. Under the Prison Litigation Reform Act of 1996, federal district courts must screen an indigent prisoner's complaint and dismiss the complaint if it is frivolous, malicious, fails to state a claim for which relief can be granted, or seeks monetary relief from a defendant who is immune from such relief. 28 U.S.C. §§ 1915(e)(2)(B) and 1915A; Flanory v. Bonn, 604 F.3d 249, 252 (6th Cir. 2010); Smith v. Campbell, 250 F.3d 1032, 1036 (6th Cir. 2001); see also Mattox v. Edelman, et al., ___ F.3d ___, ___, No. 16-1412, 2017 WL 992510, at *3 n.3 (6th Cir. Mar. 15, 2017) (stating that “28 U.S.C. § 1915(e)(2)(B)(ii) requires a district court to dismiss an [in forma pauperis] complaint if at any point it determines that the complaint ‘fails to state a claim on which relief may be granted' ”).

         A complaint is frivolous if it lacks an arguable basis in law or in fact. Neitzke v. Williams, 490 U.S. 319, 325 (1989). “A complaint is subject to dismissal for failure to state a claim if the allegations, taken as true, show the plaintiff is not entitled to relief.” Jones v. Bock, 549 U.S. 199, 215 (2007).

         While a complaint “does not need detailed factual allegations, ” the “[f]actual allegations must be enough to raise a right to relief above the speculative level on the assumption that all the allegations in the complaint are true (even if doubtful in fact).” Bell Atlantic Corp. v. Twombly, 550 U.S. 544, 555 (2007) (footnote and citations omitted). In other words, “a complaint must contain sufficient factual matter, accepted as true, ‘to state a claim to relief that is plausible on its face.' ” Ashcroft v. Iqbal, 556 U.S. 662, 678 (2009) (quoting Twombly, 550 U.S. at 570). “A claim has facial plausibility when the plaintiff pleads factual content that allows the court to draw the reasonable inference that the defendant is liable for the misconduct alleged.” Id. (citing Twombly, 550 U.S. at 556). Finally, to prevail on a claim under § 1983, a plaintiff must prove two elements: “(1) that he or she was deprived of a right secured by the Constitution or laws of the United States; and (2) that the deprivation was caused by a person acting under color of law.” Robertson v. Lucas, 753 F.3d 606, 614 (6th Cir. 2014).

         III. Analysis

         A. Excessive-Force Eighth Amendment Claims

         Plaintiff brings her complaint under the Eighth Amendment to the United States Constitution, which “applies to the States through the Due Process Clause of the Fourteenth Amendment [and] prohibits the infliction of ‘cruel and unusual punishments' on those convicted of crimes.” Wilson v. Seiter, 501 U.S. 294, 296-97 (1991) (internal citation omitted). The “settled rule” in cases where correctional officials allegedly used excessive force on inmates is “that ‘the unnecessary and wanton infliction of pain . . . constitutes cruel and unusual punishment forbidden by the Eighth Amendment.' ” Hudson v. McMillian, 503 U.S. 1, 5 (1992) (quoting Whitley v. Albers, 475 U.S. 312, 319 (1986) (quoting Ingraham v. Wright, 430 U.S. 651, 670 (1977)). “[T]he core judicial inquiry is that set out in Whitley: whether force was applied in a good-faith effort to maintain or restore discipline, or maliciously and sadistically to cause harm.” Id. at 6-7.

When prison officials maliciously and sadistically use force to cause harm, contemporary standards of decency always are violated. See Whitley, supra, 475 U.S., at 327, 106 S.Ct., at 1088. This is true ...

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