McKnight v. State
The State of Connecticut and the Department of Correction do not qualify as "persons," for purposes of civil-rights claims under 42 U.S.C. §1983. During an altercation with prison inmates in 1993, Anthony McKnight, who worked for the Department of Correction, allegedly was seriously injured. McKnight took a leave of absence from work. Allegedly, McKnight, who is African-American, was not treated the same as similarly situated workers, and he was discharged. McKnight sued and alleged that individual public officials negligently breached their fiduciary duties. The District Court found that the 11th Amendment to the U.S. Constitution barred his claim. Absent evidence that the state or its agencies waived immunity, the court dismissed the plaintiff's claim of negligent breach of fiduciary duties against state defendants. To the extent that McKnight alleged that he was entitled to benefits under Connecticut General Statutes §5-142(a), in 2001 the Connecticut Superior Court dismissed the plaintiff's request for relief, for failure to exhaust administrative remedies, and the District Court was unable to review the 2001 state court ruling under the Rooker-Feldman doctrine. McKnight also alleged that the state and state agencies violated 42 United States Code §1983. The State of Connecticut and the Department of Correction do not qualify as "persons," for purposes of civil-rights claims under 42 U.S.C. §1983, and the District Court dismissed the pro se plaintiff's §1983 count, which alleged the deprivation of a constitutionally or federally protected property right. McKnight failed to allege that he filed a complaint with the Equal Employment Opportunities Commission and exhausted administrative remedies, and the District Court dismissed his claims that the state violated Title VII of the Civil Rights Act of 1964 and the Americans With Disabilities Act. The District Court dismissed the plaintiff's federal claims and did not exercise supplemental jurisdiction over state-law claims.