Law School Case Brief
Diaz v. Wall - No. 17-94WES, 2018 U.S. Dist. LEXIS 38097 (D.R.I. Feb. 12, 2018)
Rule 12(b)(6) permits the court to dismiss an action if it fails to state a claim upon which relief can be granted.
In a hand-written complaint, pro se plaintiff Samuel Diaz, a prisoner at the Adult Correctional Institutions ("ACI"), filed a lawsuit in federal district court against defendant Asbel Wall and numerous other employees of the Rhode Island Department of Corrections ("RIDOC"); all but one defendant were named in both their individual and official capacities. Diaz's allegations loosely fell into three distinct claims. First, he alleged that, while incarcerated, he should have received medication for attention deficit disorder ("ADHD"). Second, he claimed that, despite having serious mental illness, over many years while serving multiple short sentences at the ACI, he had persistently been held in excessively harsh disciplinary confinement for a substantial portion of the time incarcerated, which had exacerbated his mental illness. Third, he sought damages for an incident at the ACI on Nov. 23, 2016, when he alleged he was sprayed with "O.C.," forced to clean waste without proper gloves or cleaning products and left without a mattress for two days and without water for six. For a remedy, Diaz asked the Court to award him compensatory damages for pain and suffering, and punitive damages for "every year that my life has gotten worse from these individuals not treating me, leading to a new injury I have to live with." The complaint did not seek injunctive relief or a declaratory remedy. Pursuant to Fed. R. Civ. P. 12(b)(6), Defendants' filed a motion to dismiss Diaz's claims against each of them, in both their individual and official capacities.
Should the court grant defendants' motion to dismiss Diaz's claims for compensatory damages for pain and suffering, and punitive damages?
The district court granted defendants' motion to dismiss. Diaz failed to state a claim upon which relief can be granted. Rule 12(b)(6) permitted the court to dismiss an action if it failed to state a claim upon which relief can be granted. To survive a motion to dismiss, a complaint must give defendant fair notice of what the claim is and the grounds upon which it rested, and allege a plausible entitlement to relief. A plaintiff must plead sufficient factual content that allows the court to draw the reasonable inference that the defendant is liable for the misconduct alleged. In evaluating a Fed. R. Civ. P. 12(b)(6) motion, the court must accept as true all well-pleaded facts alleged in the complaint and draw all reasonable inferences in the pleader's favor. The court need not credit bald assertions or unverifiable conclusions. A plaintiff's asserted facts must possess enough heft to show that he is entitled to relief.
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