Rodriguez v. MacDougall Walker C.I.
In a civil-rights suit under 42 United States Code §1983, a prison facility does not qualify as a "person," and it cannot be sued. Allegedly, the pro se plaintiff inmate, Edgardo Rodriguez, was selected to participate in a Department of Correction training exercise when he was incarcerated at the MacDougal Walker Correctional Institution. Rodriguez alleged that corrections officers ordered that he pretend to fight with another inmate and then the corrections officers pepper sprayed the inmates. Allegedly, the pepper spray became stuck in the "on" position, and Rodriguez was unable to breathe. Rodriguez allegedly lost consciousness. A doctor diagnosed Rodriguez with asthma and issued an inhaler. Rodriguez sued the MacDougal Walker Correctional Institution and individual defendants, alleging that they used excessive force, failed to protect him and were deliberately indifferent to his safety and serious medical condition, in violation of his rights under the Eighth Amendment and 42 United States Code §1983. A state correctional facility does not qualify as a "person" for purposes of §1983, and the District Court dismissed Rodriguez's claims against the MacDougal Walker Correctional Institution. The 11th Amendment provides immunity to state officials who are sued for damages in their official capacities, and the court dismissed Rodriguez's claims for monetary damages against the defendants in their official capacities. Rodriguez's claims against the defendants in their individual capacities survived, and the court ordered the defendants to file answers or motions to dismiss, on or before April 3, 2013.