Dudley v. Singleton

Citation508 F.Supp.3d 1118
Decision Date17 December 2020
Docket NumberCase No. 3:20-cv-00626-HNJ
Parties Laurie DUDLEY, Plaintiff v. Rick SINGLETON, et al., Defendants
CourtU.S. District Court — Northern District of Alabama

Kira Y. Fonteneau, Kristin Waters Sullivan, The Five Points Law Group LLC, Birmingham, AL, for Plaintiff.

J. Randall McNeill, Fred Lee Clements, Jr., Webb & Eley PC, Montgomery, AL, for Defendants.

MEMORANDUM OPINION AND ORDER

HERMAN N. JOHNSON, JR., UNITED STATES MAGISTRATE JUDGE

Plaintiff, Laurie Dudley, proceeds as the mother and Administrator of the Estate of Brandon Spann, who died while detained in the Lauderdale County Detention Center. Dudley's First Amended Complaint asserts Due Process and Equal Protection claims against corrections officers Steven Carlton and David Dison pursuant to 42 U.S.C. § 1983, and claims against Lauderdale County Sheriff Rick Singleton pursuant to Title II of the Americans with Disabilities Act (ADA) and the Rehabilitation Act (RA). (See Doc. 15). This memorandum opinion addresses Singleton's Motion to Dismiss pursuant to Federal Rule of Civil Procedure 12(b)(6) (Doc. 24), and Carlton and Dison's Motion to Dismiss pursuant to the same provision. (Doc. 26).1

As explicated below, qualified immunity protects Carlton and Dison from suit on Dudley's Due Process claim regarding Spann's suicide because they did not possess knowledge of a strong likelihood that Spann would harm himself. However, Dudley's Due Process claim regarding their delay in responding to Spann's mental health and psychiatric needs plausibly avers a violation of the Due Process Clause pursuant to clearly established law. Dudley's Equal Protection claim cannot proceed on "class of one" theory because the alleged facts do not indicate Spann was similarly situated to other detainees, and a traditional Equal Protection claim also falters given the lack of averments Carlton and Dison demonstrated animus on the basis of Spann's disability. Accordingly, the court will partially grant Carlton and Dison's motion to dismiss.

In addition, Dudley plausibly stated ADA and RA claims against Singleton in his official capacity due to his employees’ alleged failure to accommodate Spann's mental health needs. Yet she does not have standing to obtain injunctive relief for the alleged violation, and she did not allege deliberate indifference by a high enough official as to the alleged failure to accommodate so as to obtain monetary damages. Furthermore, the court will dismiss any claims that rely upon 42 U.S.C. § 1983 as a vehicle for ADA and RA claims given the existence of adequate remedies under the substantive statutes themselves. Therefore, the court will grant Singleton's motion to dismiss as to disability claims brought under those statutes.

STANDARD OF REVIEW

Federal Rule of Civil Procedure 12(b)(6) permits a court to dismiss a complaint if it fails to state a claim for which relief may be granted. In Ashcroft v. Iqbal , 556 U.S. 662, 129 S.Ct. 1937, 173 L.Ed.2d 868 (2009), the Court revisited the applicable standard governing Rule 12(b)(6) motions to dismiss. First, courts must take note of the elements a plaintiff must plead to state the applicable claims at issue. Id. at 675, 129 S.Ct. 1937.

After establishing the elements of the claim at issue, the court identifies all well-pleaded, non-conclusory factual allegations in the complaint and assumes their veracity. Id. at 679, 129 S.Ct. 1937. Well-pleaded factual allegations do not encompass mere "labels and conclusions," legal conclusions, conclusory statements, or formulaic recitations and threadbare recitals of the elements of a cause of action. Id. at 678, 129 S.Ct. 1937 (citations omitted). In evaluating the sufficiency of a plaintiff's pleadings, the court may draw reasonable inferences in plaintiff's favor. Aldana v. Del Monte Fresh Produce, N.A., Inc. , 416 F.3d 1242, 1248 (11th Cir. 2005).

Third, a court assesses the complaint's well-pleaded allegations to determine if they state a plausible cause of action based upon the identified claim's elements. Iqbal , 556 U.S. at 678, 129 S.Ct. 1937. Plausibility ensues "when the plaintiff pleads factual content that allows the court to draw the reasonable inference that the defendant is liable for the misconduct alleged," and the analysis involves a context-specific task requiring a court "to draw on its judicial experience and common sense." Id. at 678, 679, 129 S.Ct. 1937 (citations omitted). The plausibility standard does not equate to a "probability requirement," yet it requires more than a "mere possibility of misconduct" or factual statements that are "merely consistent with a defendant's liability." Id. at 678, 679, 129 S.Ct. 1937 (citations omitted).

ALLEGATIONS OF DUDLEY'S FIRST AMENDED COMPLAINT

On May 1, 2018, authorities arrested Brandon Spann for a domestic incident and transported him to the Lauderdale County Detention Center, at which he arrived at 3:35 p.m. (Doc. 15, ¶¶ 7-9). Spann possessed a small amount of marijuana at the time of the arrest, and unnamed officials placed him in a detoxification cell with other inmates upon his arrival at the Detention Center. (Id. ¶¶ 10, 14). The Detention Center maintains an incident log that details all incidents and shares important information about the detainees Center personnel guard. (Id. ¶¶ 26-27).

Around 5:10 p.m., unnamed corrections officers found Spann in the detoxification cell throwing food and with his shirt off. (Id. ¶ 15). Missy Smith, the Assistant Jail Administrator, ordered corrections officers to remove Spann from the detoxification cell and place him in a psychiatric restraint chair. (Id. ¶¶ 16-17). After spending an unspecified amount of time in the restraint chair, Spann returned to the detoxification cell. (Id. ¶ 18).

At 9:53 p.m., corrections officer Anita McDaniel commenced Spann's intake screening. (Doc. 15, ¶ 19). When McDaniel asked Spann if he experienced any serious mental health disorders that might require treatment during his detention, Spann responded that he suffered from bipolar disorder

, but he did not take any medication for the condition. (Id. ¶¶ 20-23). McDaniel indicated on the intake form that Spann had a history of severe mental illness, violently opposed authority, and displayed aggression toward others. (Id. ¶¶ 24-25).

At 11:30 p.m., unidentified officers placed Spann in a cell with several other inmates, and within minutes, the other inmates assaulted Spann. (Id. ¶¶ 28-29). corrections officers Chase Windom and Barbara Ray removed a bleeding Spann from the cell and placed him, alone, in an attorney visitation cell. (Id. ¶ 30). No officers sought immediate medical attention for Spann or provided him bandages for his bleeding wound, yet Windom and Ray logged the assault in the incident log corrections officers used to share information with other officers. (Id. ¶¶ 26-27, 31-33).

More than six hours later, during the morning of May 2, 2018, Kylie Jones, the day shift nurse, examined Spann. Spann reported that the other inmates dropped him on his face during their altercation, and Jones noted dried blood on Spann's face and a deformity on his nose

that needed an x-ray. Jones ordered that officers should place Spann in a cell with a camera. (Doc. 15, ¶¶ 35-37). The Amended Complaint does not state whether officers immediately placed Spann in a cell with a camera, but it does aver that "[s]everal hours later," Detention Center personnel moved Spann to a cell with no camera. (Id. ¶ 38). There, Spann told his cellmate, Deak Heath, that he would kill himself before he went back to prison. (Id. ¶¶ 40-41).

On May 4, 2018, at an unspecified hour, Spann kicked on his cell door, and Defendant Steven Carlton, a corrections officer on duty, went to the cell. Spann told Carlton "he did not feel right, and he needed to get out of his cell." (Id. ¶¶ 45, 47-48). Carlton responded, "As far as I am concerned, you will never come out when I am on duty," and slammed the door shut. (Id. ¶¶ 49-50).

"A little while later, Spann kicked the door again," and Defendant David Dison, another corrections officer on duty, responded. (Id. ¶¶ 46, 51-52). Spann again stated he did not "feel right," and he needed to leave the cell. (Doc. 15, ¶ 53). Like Carlton, Dison told Spann he would not leave the cell while Dison was on duty. (Id. ¶¶ 74, 91). Carlton and Dison did not call the nurse or check on Spann again. (Id. ¶¶ 54-55). Jail policy allows inmates to leave their cells "for various purposes throughout the day," and Spann had not received any disciplinary sanctions that would prevent him from leaving his cell or accessing health care. (Id. ¶¶ 42-44).

At an unspecified later time on May 4, 2018, corrections officers allowed another inmate, Daniel Odom, who did not suffer a disability and had not asked for help, to leave his cell. Odom walked to Spann's cell and found Spann hanging from a bed sheet tied to his bunk. Odom reported the hanging to Carlton, who cut Spann down but did not immediately provide medical aid because he did not possess a CPR certification. Instead, Carlton summoned other corrections officers to attempt to resuscitate Spann. Officers eventually transported Spann to a hospital, where he died from his hanging. (Id. ¶¶ 56-65).

Dudley asserts that Carlton and Dison, in their individual capacities, violated the Due Process Clause of the United States Constitution by failing to provide care for Spann's deteriorating mental health and failing to prevent Spann from harming himself. (Id. ¶¶ 78-99). She asserts that Carlton and Dison violated Spann's Equal Protection rights when they allowed other, non-disabled inmates to leave their cells, but did not allow Spann, who suffered from a mental health disability, to leave his cell to address his mental health. (Doc. 15, ¶¶ 100-122).

Dudley also asserts Carlton and Dison failed to accommodate Spann's mental health disability and treated him differently because of his disability, thereby denying Spann the benefits...

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