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Wainwright v. Medical Department Cuyahoga County Correctional Center

United States District Court, N.D. Ohio

July 23, 2018

JONATHAN L. WAINWRIGHT, Plaintiff,
v.
MEDICAL DEPARTMENT CUYAHOGA COUNTY CORRECTIONAL CENTER, et al., Defendants.

          OPINION & ORDER [RESOLVING DOCS. 47, 49]

          JAMES S. GWIN, UNITED STATES DISTRICT JUDGE

         Plaintiff Jonathan L. Wainwright, pro se, brings this suit after he slipped and fell in a shower while incarcerated at the Cuyahoga County Correctional Center.[1] The Court previously dismissed several of Plaintiff's claims against the Cuyahoga County Defendants.[2] The County Defendants have now moved for renewed judgment on the pleadings and for summary judgment on Plaintiff's sole surviving Americans with Disabilities Act (ADA) claims.[3] Plaintiff has not filed any opposition to either motion.

         For the following reasons, the Court GRANTS the motion for judgment on the pleadings on Plaintiff's ADA claims. Defendants' motion for summary judgment is therefore MOOT.

         I. BACKGROUND

         On May 4, 2018, the Court granted the MetroHealth Defendants'[4] and the Cuyahoga County Defendants' motions for judgment on the pleadings on several of Plaintiff's claims. Because the County Defendants did not move for judgment on the pleadings on Plaintiff's ADA claims against it, those claims survived.

         On May 11, 2018, the County Defendants moved to file a supplemental motion for judgment on the pleadings on Plaintiff's ADA claims against them.[5] The Court granted that motion and gave Plaintiff until July 4, 2018, to oppose.[6] Plaintiff has failed to file any opposition by that time.[7]

         In considering the County Defendants' motion for judgment on the pleadings, the Court refers to its previous description of Plaintiff's allegations in its May 4 opinion and order.[8]

         II. LEGAL STANDARD

         Although federal courts are obligated to construe pro se complaints liberally, [9] such principles are not without limits.[10] Plaintiffs proceeding pro se must still meet basic pleading standards, and courts are not required to “conjure allegations on [their] behalf.”[11]

         On a motion for judgment on the pleadings under Federal Rule of Civil Procedure 12(c), the Court employs the same standard as a motion to dismiss for failure to state a claim upon which relief can be granted under Rule 12(b)(6).[12]

         Thus, “‘[f]or purposes of a motion for judgment on the pleadings, all well-pleaded material allegations of the pleadings of the opposing party must be taken as true, and the motion may be granted only if the moving party is nevertheless clearly entitled to judgment.'”[13] The plaintiff need not try to prove his case in the complaint. But there must be “more than a sheer possibility that the defendant has acted unlawfully.”[14]

         III. ANALYSIS

         The Court dismisses Plaintiff's ADA claims against the County Defendants.[15]

         The Court liberally construes Plaintiff's complaint as asserting ADA claims under Title II, 42 U.S.C. § 12131 against the County Defendants.

         As a preliminary matter, the Court finds that Plaintiff does not lack standing to bring his ADA claims. The County Defendants argue that Plaintiff lacks standing because he did not specifically request handicap shower access or medical pod housing.[16] This argument appears to assert that Plaintiff's injuries are not directly traceable to the County Defendants' denial of accommodation if Plaintiff never requested any such accommodation in the first place.

         To establish Article III standing, Plaintiff must allege facts sufficient to show: (1) an “injury-in-fact, ” which is “concrete and particularized” and “actual or imminent, not conjectural or hypothetical;” (2) “the injury is fairly traceable to the challenged action of the defendant;” and (3) “it is likely, as opposed to merely speculative, that the injury will be redressed by a favorable decision.”[17]

         Plaintiff Wainwright alleged those requirements. Plaintiff alleged that he suffered physical injuries when he slipped in the prison shower, and that those injuries were a result of the County Defendants' denial of his two requests for a shower ...


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