Williams v. Taylor
Filing
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RECOMMENDED DISPOSITION recommending 1 Mr. Williams' complaint be dismissed, without prejudice; in the future, this dismissal be considered a "strike"; the Court certify that an in forma pauperis appeal of this dismissal would be frivolous and not taken in good faith; and the Clerk be directed to close this case. Objections due within 14 days of the date of this Recommendation. Signed by Magistrate Judge Edie R. Ervin on 03/05/2025. (llg)
IN THE UNITED STATES DISTRICT COURT
EASTERN DISTRICT OF ARKANSAS
CENTRAL DIVISION
ANTUAN WILLIAMS
ADC #151064
V.
PLAINTIFF
NO. 4:25-cv-00128-BRW-ERE
LATASHIA TAYLOR
DEFENDANT
RECOMMENDED DISPOSITION
I.
Procedure for Filing Objections:
This Recommendation has been sent to United States District Judge Billy Roy
Wilson. You may file written objections to all or part of this Recommendation. Any
objections filed must: (1) specifically explain the factual and/or legal basis for the
objection; and (2) be received by the Clerk of this Court within fourteen (14) days
of the date of this Recommendation. If you do not object, you risk waiving the right
to appeal questions of fact and Judge Wilson can adopt this Recommendation
without independently reviewing the record.
II.
Background:
On February 12, 2025, pro se plaintiff Antuan Williams, an Arkansas Division
of Correction (“ADC”) inmate, filed this civil rights lawsuit under 42 U.S.C. § 1983.
Doc 1. Mr. Williams’ complaint alleges that, on January 13, 2025, Lieutenant
Latashia Taylor was deliberately indifferent to his safety by: (1) placing him in an
unsanitary shower for several hours; and (2) forcing him to eat a meal in the alleged
unconstitutional conditions. Mr. Williams sues Lieutenant Taylor in both her
individual and official capacities seeking monetary damages.
The Court now recommends that Mr. Williams’ conditions of confinement
claims against Lieutenant Taylor be DISMISSED, without prejudice, for failure to
state a plausible constitutional claim for relief.
III.
Discussion:
A.
Standard
The Prison Litigation Reform Act requires federal courts to screen prisoner
complaints and to dismiss any claims that: (a) are legally frivolous or malicious; (b)
fail to state a claim upon which relief may be granted; or (c) seek monetary relief
from a defendant who is immune from such relief. See 28 U.S.C. § 1915A(a) & (b).
When making this determination, a court must accept the truth of the factual
allegations contained in the complaint, and it may consider documents attached to
the complaint. Ashcroft v. Iqbal, 556 U.S. 662, 678 (2009); Reynolds v. Dormire,
636 F.3d 976, 979 (8th Cir. 2011).
In deciding whether Mr. Williams has stated a plausible claim for relief under
§ 1983, the Court must determine whether the allegations in the complaint, which
are presumed true, “raise a right to relief above the speculative level.” Bell Atlantic
Corp. v. Twombly, 550 U.S. 544, 555 (2007) (citations omitted). A complaint cannot
simply “[leave] open the possibility that a plaintiff might later establish some ‘set of
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undisclosed facts’ to support recovery.” Id. at 561 (citation omitted). Rather, the
facts set forth in the complaint must “nudge [the] claims across the line from
conceivable to plausible.” Id. at 570.
B.
Conditions of Confinement Claim
To move forward on an inhumane conditions of confinement claim, Mr.
Williams must allege facts which, taken as true, support a reasonable inference that
he suffered a serious deprivation of “the minimal civilized measure of life’s
necessities” and the “offending conduct [was] wanton.” Wilson v. Seiter, 501 U.S.
294, 298 (1991). “The defendant’s conduct must objectively rise to the level of a
constitutional violation by depriving the plaintiff of the minimal civilized measure
of life’s necessities. The defendant’s conduct must also reflect a subjective state of
mind evincing deliberate indifference to the health or safety of the prisoner.” Revels
v. Vincenz, 382, F.3d 870, 875 (8th Cir. 2004) (citations and quotation marks
omitted).
Mr. Williams’ complaint fails to allege facts suggesting that Lieutenant Taylor
either: (1) denied him any of life’s necessities; or (2) disregarded an excessive risk
to his health or safety. Mr. Williams’ allegations regarding unpleasant conditions of
his confinement for several hours on one day fall short of alleging that he suffered
an extreme deprivation violating his constitutional rights. See Goldman v. Forbus,
17 Fed. Appx. 487, 488 (8th Cir. 2001) (unpublished opinion) (six nights sleeping
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on the floor and being sprinkled with urine was not a constitutional violation);
Seltzer-Bey v. Delo, 66 F.3d 961, 963-64 (8th Cir. 1995) (no constitutional violation
where inmate was in strip cell for two days without clothing, bedding, or running
water, with a concrete slab for a bed, and cold air blowing on him); and Pillow v.
Ryals, 2020 WL 6445917, *3 (E.D. Ark. Nov. 3, 2020) (“six-day exposure to
disgusting smells from an overflowing toilet, twenty-nine days without hot water in
the sinks in his cell, exposure to water into his bunk from a leaking window when it
rained, which required him to occasionally sleep on the floor, and a leaking sink”
failed to establish a constitutional violation).
IV.
Conclusion:
IT IS THEREFORE RECOMMENDED THAT:
1.
Mr. Williams’ complaint should be DISMISSED, without prejudice,
based on his failure to state a plausible constitutional claim for relief.
2.
In the future, this dismissal be considered a “strike” for purposes of 28
U.S.C. § 1915(g).
3.
The Court certify that an in forma pauperis appeal of this dismissal
would be frivolous and not taken in good faith.
4.
The Clerk be directed to close this case.
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Dated 5 March 2025.
____________________________________
UNITED STATES MAGISTRATE JUDGE
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