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Williams v. Trent

United States District Court, W.D. Virginia, Roanoke Division

September 19, 2017

TRENT, et al., Defendants.



         Rashand Williams, a Virginia inmate proceeding pro se, filed a civil rights action pursuant to 28 U.S.C. § 1983, alleging that the defendants denied him adequate medical treatment and used excessive force against him. Defendants filed motions to dismiss and Williams responded, making this matter ripe for disposition. Having reviewed the record, I conclude that defendants' motions must be granted as to defendants Cox and Trent and denied as to defendants Hairston, Bramblett-Robinson, and Hartman.


         Williams alleges that upon arriving at the Western Virginia Regional Jail on April 12, 2016, he met with medical staff and informed them of his allergies, including medication to which he is allergic. On September 9, 2016, while experiencing a migraine and tension headache, Williams asked defendant Hairston, a medication technician, for pain medicine and she told him that he could not take aspirin or Tylenol because he was allergic to them. Instead, Nurse Hairston gave Williams Excedrin[1] twice a day for two days. Williams states that Hairston did not “thoroughly” review his medical file or refer him to the nurse practitioner or doctor before giving him the Excedrin.

         On September 10, 2016, Williams submitted a health care request form, notifying medical staff that he had a “sharp pain” in his head. Williams states that “during this time, ” his headaches and stomach pain became “severe” and “unbearable” and he had uncontrollable bowel movements. Williams alleges that on September 12, 2016, the doctor notified medical staff that Williams could not receive Excedrin because it has aspirin in it.

         On September 14, 2016, Williams submitted another health care request form notifying medical staff of his allergies to aspirin and Tylenol.[2] On September 15, 2016, Williams saw defendant Bramblett-Robinson, a physician assistant, who told him that there was “nothing they could give” him. Williams alleges that she “sent for” his medical records concerning his allergic reaction to aspirin and Tylenol.

         On September 22, 2016, Williams sent another health care request form, notifying medical staff of his abdominal pain and migraine headaches, and that he had been denied medical attention. On October 7, 2016, after a nurse came to distribute medication to the unit where Williams was housed, Officer Kought told Williams to “lock down” for twenty-four hours. Williams alleges that the nurse had told Officer Kought that Williams did not take his medication. Williams walked to his cell with Officer Kought and defendant Officer Hartman. Upon arriving at his cell, Williams stood in the doorway, and while he was “not refusing or ac[t]ing out, ” Officer Hartman pushed Williams into the cell, then “came with a blow to the face, caus[]ing [his] head to hit the wall very hard and [then] came with another blow to [his] stomach” causing Williams to “suffer[] a lot of pain in [his] stomach and [a] cluster migraine.” A supervisor arrived after the incident, asked Williams what had happened, and then placed Williams in segregation. Williams alleges that he was denied medical treatment for his stomach pain and cluster migraine. He also alleges that his request for a grievance was denied.


         Defendants filed motions to dismiss Williams' complaint.[3] A motion to dismiss pursuant to Federal Rule of Civil Procedure 12(b)(6) tests the legal sufficiency of a complaint to determine whether the plaintiff has properly stated a claim; “it does not resolve contests surrounding the facts, the merits of a claim, or the applicability of defenses.” Republican Party of N.C. v. Martin, 980 F.2d 943, 952 (4th Cir. 1992). In considering a Rule 12(b)(6) motion, a court must accept all factual allegations in the complaint as true and must draw all reasonable inferences in favor of the plaintiff. Erickson v. Pardus, 551 U.S. 89, 94 (2007). Legal conclusions in the guise of factual allegations, however, are not entitled to a presumption of truth. Ashcroft v. Iqbal, 556 U.S. 662 (2009).

         Although a complaint “does not need detailed factual allegations, a plaintiffs obligation to provide the grounds of his entitle[ment] to relief requires more than labels and conclusions, and a formulaic recitation of a cause of action's elements will not do.” Bell Atl. Corp. v. Twombly, 550 U.S. 544, 555 (2007) (citations and quotations omitted). “Factual allegations must be enough to raise a right to relief above the speculative level, ” id., with all the allegations in the complaint taken as true and all reasonable inferences drawn in the plaintiffs favor, Chao v. Rivendell Woods, Inc., 415 F.3d 342, 346 (4th Cir. 2005). Rule 12(b)(6) does “not require heightened fact pleading of specifics, but only enough facts to state a claim to relief that is plausible on its face.” Twombly, 550 U.S. at 570. Consequently, “only a complaint that states a plausible claim for relief survives a motion to dismiss.” Iqbal, 556 U.S. at 679 (citing Twombly, 550 U.S. at 556). A claim is plausible if the complaint contains “factual content that allows the court to draw the reasonable inference that the defendant is liable for the misconduct alleged, ” and if there is “more than a sheer possibility that a defendant has acted unlawfully.” Id.. at 678.

         In order to allow for the development of a potentially meritorious claim, federal courts have an obligation to construe pro se pleadings liberally. See, e.g., Boag v. MacDougall, 454 U.S. 364, 365 (1982) (citation omitted). Moreover, “[l]iberal construction of the pleadings is particularly appropriate where . . . there is a pro se complaint raising civil rights issues.” Smith v. Smith, 589 F.3d 736, 738 (4th Cir. 2009) (quoting Loe v. Armistead, 582 F.2d 1291, 1295 (4th Cir. 1978)). Nevertheless, “[p]rinciples requiring generous construction of pro se complaints are not . . . without limits.” Beaudett v. City of Hampton, 775 F.2d 1274, 1278 (4th Cir. 1985). “A pro se plaintiff still must allege facts that state a cause of action.” Bracey v. Buchanan, 55 F.Supp.2d 416, 421 (E.D. Va. 1999) (quoting Sado v. Leland Mem'l Hospital, 933 F.Supp. 490, 493 (D. Md. 1996)).


         Williams alleges that defendants Hairston and Bramblett-Robinson denied him adequate medical treatment. I conclude that Williams' allegations state a plausible Eighth Amendment claim against these defendants and, therefore, I will deny their motion to dismiss.

         To state a cognizable Eighth Amendment claim for denial of medical care, a plaintiff must allege facts sufficient to demonstrate that jail officials were deliberately indifferent to a serious medical need. Estelle v. Gamble, 429 U.S. 97, 105 (1976); Staples v. Va. Dep't of Corr., 904 F.Supp. 487, 492 (E.D.Va. 1995). To establish deliberate indifference, a plaintiff must present facts to demonstrate that the defendant had actual knowledge of and disregard for an ...

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