Webb v. Armstrong
A court can deny an inmate's request to add new claims to his allegations that corrections officials retaliated and used excessive force, and conditions of confinement were inhumane. In March 2010, Daniel Webb, a death-row inmate at Northern Correctional Institution, allegedly lunged and swung at Captain Jason Cahill, because he believed Cahill had been disrespectful to Webb and his family. Corrections officials allegedly beat Webb, sprayed chemicals and placed Webb in painfully tight restraints that caused permanent injuries. Webb's complaint alleged that he remained in four-point restraints for eight hours and in in-cell restraints for three days, and that the restraints were too tight, the temperature was freezing, and he had to eat with his hands, which were coated with fecal matter, because he was denied soap and utensils. Webb filed a complaint, alleging excessive use of force, retaliation in violation of the First Amendment and inhumane conditions of confinement, in violation of the Eighth Amendment. The District Court previously dismissed Webb's claims against 20 of the 28 defendants and ordered Webb to identify and to file a complaint against a John Doe defendant within 30 days. The earlier court decision cautioned the plaintiff that "the amended complaint shall . . . omit all allegations relating to the claims that have been dismissed." The plaintiff responded with a "proposed" amended complaint that included new requests for relief and that for the first time claimed that the defendants violated the Americans With Disabilities Act. The District Court treated the "proposed" amended complaint as a motion for leave to file an amended complaint, and it denied the motion. The court ordered the plaintiff to file a new amended complaint that does not include new or unauthorized claims or defendants, on or before Jan. 18, 2013.