Eden v. Dunigan et al

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UNITED STATES DISTRICT COURT
EASTERN DISTRICT OF MICHIGAN
SOUTHERN DIVISION
JESSE EDEN,
Plaintiff,
v.
DUNIGAN, et al.,
Defendants.
/
Case No. 2:25-cv-12060
HONORABLE STEPHEN J. MURPHY, III
OPINION AND ORDER PARTIALLY DISMISSING CASE
Plaintiff Jesse Eden, currently confined at the Carson City Correctional
Facility in Carson City, Michigan, filed a pro se civil rights complaint under 42 U.S.C.
§ 1983. The case was transferred from the United States District Court for the
Western District of Michigan. See ECF No. 4. For the reasons below, the Court will
dismiss the Amended Complaint, in part, pursuant to 28 U.S.C. §§ 1915(e)(2)(B) and
1915A(b)(1) for failure to state a claim upon which relief may be granted.
BACKGROUND
Eden’s 	claims 	arose 	during 	his 	incarceration 	at 	the 	G. 	Robert 	Cotton
Correctional (JCF) facility in Jackson, Michigan. ECF No. 4, PageID.54. He sued the
following JCF staff:
 	Corrections Officer Dunigan
 	Corrections Officer Whiting
 	Maintenance Supervisor John/Jane Doe
 	“Jon Doe #5,” identified as the “Officer who handcuffed injured wrist”
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 	“Health Care Personnel,” including “Nurse Jane Doe #1.”
 	“Other Parties to be Determined”
 	“Respondent Superior” [sic]
ECF No. 3, PageID.41–42, 45.1
Eden alleged that on December 6, 2024, while walking through a hallway, he
tripped and fell over a doorstop stuck to the floor, injuring his knee, left elbow, wrist,
and arm. Id. at PageID.47. Eden asked C.O. Dunigan to go to the medical unit for
treatment. Dunigan denied the request and said, “medical don’t really care.” Id. “C.O.
Whiting was present and heard Plaintiff ask C.O. Dunigan if he could be seen by
medical.” Id. Eden alleged that he filed medical kites concerning treatment for his
injuries and grievances concerning the unsafe conditions that caused him to fall.
Eden marked his medical kites as “urgent.” Id. at PageID.48. One month later, Eden
received treatment and was provided with prescription medication. Id. at PageID.49.
An X-ray revealed disfigurement and nerve damage to his wrist. Id. Eden sued
Defendants in their individual capacitiesseeking monetary relief. Id. at PageID.44.
The Court allowed Eden to proceed in forma pauperis. ECF No. 7.
LEGAL STANDARD
Under the Prison Litigation Reform Act of 1996 (“PLRA”), the Court is required
to sua sponte dismiss an in forma pauperis complaint before service if it determines
1 Plaintiff originally filed one civil rights action with claims from three different
correctional facilities in Michigan. See generally ECF No. 1. The district court severed
the cases and ordered Plaintiff to file an amended complaint after determining that
the claims were misjoined. See ECF No. 4 (discussing history of case). Plaintiff then
filed an Amended Complaint naming only the JCF defendants. ECF No. 3.
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that the action is frivolous or malicious, fails to state a claim upon which relief can
be granted, or seeks monetary relief from a defendant who is immune from such relief.
See 42 U.S.C. § 1997e(c); 28 U.S.C. § 1915(e)(2)(B). The Court is similarly required to
dismiss 	a 	complaint 	seeking 	relief 	against 	government 	entities, 	officers, 	and
employees that is frivolous or malicious, fails to state a claim upon which relief may
be granted, or seeks monetary relief from a defendant who is immune from such relief.
See 28 U.S.C. § 1915A. A complaint is frivolous if it lacks an arguable basis in law or
in fact. Denton v. Hernandez, 504 U.S. 25, 31 (1992); Neitzke v. Williams, 490 U.S.
319, 325 (1989).
A pro se civil rights complaint is to be construed liberally. See Haines v. Kerner,
404 U.S. 519, 520-521 (1972). But Federal Rule of Civil Procedure 8(a) requires that
a complaint set forth “a short and plain statement of the claim showing that the
pleader is entitled to relief,” as well as “a demand for the relief sought.” Fed. R. Civ.
P. 8(a)(2), (3). The purpose of the rule is to “give the defendant fair notice of what the
claim is and the grounds upon which it rests.” Bell Atlantic Corp. v. Twombly, 550
U.S. 544, 555 (2007) (citation modified). Although the notice pleading standard does
not require “detailed” factual allegations, it does require more than the bare assertion
of legal conclusions. Id. Rule 8 thus “demands more than an unadorned, the-
defendant-unlawfully-harmed-me accusation.” Ashcroft v. Iqbal, 556 U.S. 662, 678
(2009). “A pleading that offers ‘labels and conclusions’ or ‘a formulaic recitation of the
elements of a cause of action will not do.’” Id. (quoting Twombly, 550 U.S. at 555).
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“Nor does a complaint suffice if it tenders ‘naked assertion[s]’ devoid of ‘further
factual enhancement.’” Id. (quoting Twombly, 550 U.S. at 557).
To state a civil rights claim under 42 U.S.C. § 1983, a plaintiff must allege (1)
he was deprived of a right, privilege, or immunity secured by the federal Constitution
or laws of the United States; and (2) the deprivation was caused by a person acting
under color of state law. See Flagg Bros. v. Brooks, 436 U.S. 149, 155–57 (1978).
DISCUSSION
I. 	Personal Involvement
First, Eden’s claims against Maintenance Supervisor John/Jane Doe, “Jon Doe
#5,” “Health Care Personnel,” “Other Parties to be Determined, and “Respondent
Superior” must be dismissed because Eden failed to allege any facts demonstrating
their personal involvement. It is well-settled that a civil rights plaintiff must allege
the personal involvement of a defendant to state a claim under 42 U.S.C. § 1983. See
Monell v. Dep’t of Social Svs., 436 U.S. 658, 691–92 (1978) (holding that § 1983
liability cannot be based upon a theory of respondeat superior or vicarious liability);
see also Taylor v. Mich. Dep’t of Corr., 69 F.3d 76, 80–81 (6th Cir. 1995) (holding that
§ 1983 plaintiffs must allege facts showing that the defendant participated, condoned,
encouraged, or knowingly acquiesced in the alleged misconduct).
Although Eden identified Defendants in the caption of his complaint, he failed
to explain their role in the alleged violations in the body of his complaint. “Merely
listing names in the caption of the complaint and alleging constitutional violations in
the body of the complaint” is insufficient to satisfy these basic pleading requirements.
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Gilmore v. Corr. Corp. of Am., 92 F. App’x 188, 190 (6th Cir. 2004); see also Frazier v.
Michigan, 41 F. App'x 762, 764 (6th Cir. 2002) (affirming dismissal of complaint in
which plaintiff “failed to allege with any degree of specificity which of the named
defendants were personally involved in or responsible for each of the alleged
violations of his federal rights.”).
Here, Eden failed to allege with any degree of specificity how each of these
Defendants were personally involved in or responsible for the alleged violations.
Because Eden failed to sufficiently allege personal involvement by Maintenance
Supervisor John/Jane Doe, “Jon Doe #5,” “Health Care Personnel,” “Other Parties to
be Determined, and “Respondent Superior,” the claims against these defendants
must be dismissed.
II. 	Deliberate Indifference to Serious Medical Needs
Next, 	Eden 	alleged 	that 	Defendants 	Dunigan 	and 	Whiting 	acted 	with
deliberate indifference to his serious medical needs when he requested medical
attention for his injuries and Dunigan denied the request. He further claimed that
the Maintenance Supervisor acted with deliberate indifference to his safety.
The Supreme Court held in Estelle v. Gamble, 429 U.S. 97 (1976), that the
deliberate indifference to a serious medical need of a prisoner constitutes unnecessary
and wanton infliction of pain in violation of the Eighth Amendment. Id. at 103. The
claim is comprised of an objective and a subjective component. The objective
component requires a “’sufficiently serious’ medical need.” Farmer v. Brennan, 511
U.S. 825, 834 (1994) (quoting Wilson v. Seiter, 501 U.S. 294, 298 (1991)). That means
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a need “that has been diagnosed by a physician as mandating treatment or one that
is so obvious that even a lay person would easily recognize the necessity for a doctor’s
attention.” Harrison v. Ash, 539 F.3d 510, 518 (6th Cir. 2008) (quoting Blackmore v.
Kalamazoo County, 390 F.3d 890, 897 (6th Cir. 2004)).
To satisfy the subjective component, a prison official “must both be aware of
facts from which the inference could be drawn that a substantial risk of serious harm
exists, and he must also draw the inference.” Farmer, 511 U.S. at 837. Deliberate
indifference “entails something more than mere negligence,” but it can be “satisfied
by something less than acts or omissions for the very purpose of causing harm or with
knowledge that harm will result.” Id. at 835.
A. 	Officer Dunigan
In his complaint, Eden alleged that immediately after his fall, he approached
Officer Dunigan and requested to be seen by medical personnel. Dunigan denied the
request and stated, “Medical don’t really care.” ECF No. 3, PageID.47. That same
day, Eden completed a medical kite requesting to be seen for his injuries to his elbow,
wrist, and knee. He was seen approximately one month later, and an X-ray revealed
disfigurement and nerve damage to his wrist. The injury was serious enough to
require medication and physical therapy.
The Court finds on initial screening that Eden has sufficiently shown that he
suffered an objectively serious medical need. Serious needs include those “so obvious
that even a lay person would easily recognize the necessity for a doctor’s attention.’”
Jones v. Muskegon County, 625 F.3d 935, 941 (6th Cir. 2010) (quoting Harrison, 539
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F.3d at 518). Here, Eden alleged that he suffered nerve damage and disfigurement in
his wrist from the fall. As a result of the injury, he also required medication and
physical therapy. Based on the injury and treatment—not to mention Eden’s own
request for medical care—the need for medical attention would have been obvious to
Officer Dunigan. Eden thus satisfies the objective prong.
The Court also finds that Eden sufficiently alleged facts showing that Officer
Dunigan acted with deliberate indifference under the subjective prong. As discussed,
Eden’s injury to his wrist would have been obvious even to a lay person. And after
Eden asked for medical treatment, Officer Dunigan would have known that his
refusal to allow Eden to seek immediate treatment could have prolonged or worsened
the injury. Accordingly, Eden will be allowed to proceed on his deliberate indifference
claims against Defendant Officer Dunigan.
The same logic applies to Officer Whiting. Of course, “mere presence at the
scene of a constitutional violation, without a showing of direct responsibility for the
action, will not subject an officer to liability.” Fazica v. Jordan, 926 F.3d 283, 289 (6th
Cir. 2019) (citation modified). Here, however, Eden alleged that “C.O. Whiting was
present and heard Plaintiff ask C.O. Dunigan if he could be seen by medical.” ECF
No. 3, PageID.47. Whiting’s alleged physical presence, knowledge of the serious
medical condition, and decision to do nothing could be enough to subject him to
liability. Eden can proceed on his deliberate indifference claim against Whiting.
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B. 	Maintenance Supervisor
Next, Eden claimed that the Maintenance Supervisor exposed him to a
dangerous situation by failing to remove the doorstop or warn of its presence. But
that is not enough to state a claim.
A prisoner can bring a Section 1983 claim by showing that the prison officials
acted with “deliberate indifference” to his health or safety. Farmer v. Brennan, 511
U.S. 825, 828–29 (1994). But “[t]he Due Process Clause is simply not implicated by a
negligent act of an official causing unintended loss of or injury to life, liberty, or
property.” Daniels v. Williams, 474 U.S. 327, 328 (1986) (emphasis in original); see
also Lewellen v. Metro. Gov’t of Nashville & Davidson County, 34 F.3d 345, 348 (6th
Cir. 1994) (“[I]t is now firmly settled that injury caused by negligence does not
constitute a ‘deprivation’ of any constitutionally protected interest.”).
Likewise, an Eighth Amendment claim of deliberate indifference must be
supported by more than mere negligence. See Harrison v. Ash, 539 F.3d 510, 522 (6th
Cir. 2008). “Negligent exposure to a risk is not sufficient to create an Eighth
Amendment violation.” Hadix v. Johnson, 367 F.3d 513, 525 (6th Cir. 2004) (citing
Farmer, 511 U.S. at 835–36). “[F]ederal courts have nearly unanimously held that a
slip and fall, without more, does not amount to cruel and unusual punishment.” Lamb
v. Howe, 677 F. App’x 204, 208 (6th Cir. 2017) (citation modified).
Eden’s claim that he tripped and fell over a doorstop alleges, at most, that the
Maintenance Supervisor was negligent in failing to protect him from a hazardous
condition. Eden thus does not state a claim for relief under Section 1983. See White
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v. Tyszkiewicz, 27 F. App’x 314, 315 (6th Cir. 2001) (affirming dismissal of slip and
fall claim by prisoner). The Court will therefore dismiss the claim against the
Maintenance Supervisor.
ORDER
WHEREFORE, 	it 	is 	hereby 	ORDERED 	that 	the 	claims 	against 	all
Defendants, except for Dunigan and Whiting, are DISMISSED.
IT IS FURTHER ORDERED that Plaintiff’s claims against Defendants
Dunigan and Whiting survive the Court’s initial screening process under 28 U.S.C.
§§ 1915(e)(2)(b) and 1915A and are not subject to summary dismissal.
SO ORDERED.
s/ Stephen J. Murphy, III
STEPHEN J. MURPHY, III
United States District Judge
Dated: October 22, 2025
I hereby certify that a copy of the foregoing document was served upon the parties
and/or counsel of record on October 22, 2025, by electronic and/or ordinary mail.
s/ R. Loury
Case Manager
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