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Battle v. South Carolina Department of Corrections

United States District Court, D. South Carolina, Charleston Division

December 20, 2019

Korell Battle, Plaintiff,
v.
South Carolina Department of Corrections; Warden Cecilia Reynolds, individually and in her official capacity as Warden of Lee Correctional Institution; and Warden Aaron Joyner, individually and in his official capacity as Warden of Lee Correctional Institution, Defendants. Darnell Brown, Plaintiff,
v.
South Carolina Department of Corrections; Warden Cecilia Reynolds, individually and in her official capacity as Warden of Lee Correctional Institution; and Warden Aaron Joyner, individually and in his official capacity as Warden of Lee Correctional Institution, Defendants. Ronnie Drake, Plaintiff,
v.
South Carolina Department of Corrections; Warden Cecilia Reynolds, individually and in her official capacity as Warden of Lee Correctional Institution; and Warden Aaron Joyner, individually and in his official capacity as Warden of Lee Correctional Institution, Defendants. Lance Lyles, Plaintiff,
v.
South Carolina Department of Corrections; Warden Cecilia Reynolds, individually and in her official capacity as Warden of Lee Correctional Institution; and Warden Aaron Joyner, individually and in his official capacity as Warden of Lee Correctional Institution, Defendants. John Mack, Plaintiff,
v.
South Carolina Department of Corrections; Warden Cecilia Reynolds, individually and in her official capacity as Warden of Lee Correctional Institution; and Warden Aaron Joyner, individually and in his official capacity as Warden of Lee Correctional Institution, Defendants.

          ORDER

          Timothy M. Cain United States District Judge.

         The above-captioned cases arise from alleged incidents of prison violence occurring in 2016 and 2017 at Lee Correctional Institution (“LCI”) in Bishopville, South Carolina. Originally, the plaintiffs in each of these actions were co-plaintiffs in a single action filed in South Carolina state court alleging federal and state law claims against Defendants South Carolina Department of Corrections (“SCDC”); Warden Cecilia Reynolds, individually and in her official capacity as Warden of LCI (“Warden Reynolds”); and Warden Aaron Joyner, individually and in his official capacity as Warden of LCI (“Warden Joyner”). (ECF No. 1-1). The original action was removed to federal court, (ECF No. 1), and the court subsequently severed it into separate actions. (ECF No. 81).[1] In accordance with 28 U.S.C. § 636(b)(1) and Local Civil Rule 73.02, D.S.C., this matter was referred to a magistrate judge for pretrial handling. Defendants filed identical motions for partial summary judgment in each of the above-captioned cases. (ECF No. 106). Plaintiffs filed a joint response in opposition to partial summary judgment, (ECF No. 110), and the magistrate judge conducted a hearing, (ECF No. 112).

         This matter is now before the court on the magistrate judge's Report and Recommendation (“Report”), recommending that the court dismiss Plaintiffs' § 1983 claims against SCDC and that the court deny Defendants' request that the court decline to exercise supplemental jurisdiction over Plaintiffs' remaining state law claims against SCDC. (ECF No. 120). Defendants filed objections to the Report (ECF No. 123), and Plaintiffs filed a reply (ECF No. 125) .

         I. Background

         Plaintiffs allege that while they were incarcerated at LCI in 2016 and 2017, they were subjected to similar attacks by other inmates as a result of Defendants' “system-wide failures” to ensure inmate safety and, in particular, their failure to control “the use of illegal contraband weapons” at LCI. (ECF No. 21 at 6). Plaintiffs allege that in each case, the attacks occurred when correctional officers “abandoned their posts, ” left “cell or wing doors unlocked, ” or otherwise acted in violation of SCDC's policies and procedures. Id. at 7. Moreover, Plaintiffs allege that Defendants “were aware of these deficiencies and substandard patterns and practices within SCDC” but failed to correct them even though they knew “their failure[] to correct these substandard patterns or practices would lead to serious bodily injury [to] the Plaintiffs.” Id. at 6. Plaintiffs further allege that these failures, including the substandard performance of LCI's correctional officers, resulted from Defendants' “gross[ly] negligen[t]” failure “to employ sufficient correctional officers, . . . to enforce its policies and procedures, [or] . . . to train or retrain its correctional officer[s] to comply with the existing policies and procedures, ” as well as their “grossly negligent, reckless, willful, wanton, and/or deliberate[ly] indifferent actions.” Id. at 8.

         Plaintiffs assert identical claims pursuant to 42 U.S.C. § 1983, alleging that all three Defendants abridged their rights under the Fifth, Eighth and Fourteenth Amendments. (ECF No. 21 at 9-13). Plaintiffs also assert claims against SCDC under the South Carolina Tort Claims Act. See S.C. Code. Ann. § 15-78-10 et seq. (ECF No. 21 at 13-15). Plaintiffs seek injunctive relief; actual, consequential and punitive damages; and attorney fees and costs. Id. at 15-16.

         Defendants filed this motion for partial summary judgment, seeking dismissal of Plaintiffs' § 1983 claims only as to Defendant SCDC. (ECF No. 106-1 at 7-9). Defendants argue that because SCDC, a state agency, has not waived its immunity under the Eleventh Amendment, Plaintiffs cannot maintain claims against it under § 1983. Id. Additionally, Defendants argue that if the court dismisses Plaintiffs' § 1983 claims against SCDC, the court should decline to exercise supplemental jurisdiction over the state law claims against SCDC that remain. Id. at 9-10. After initially opposing Defendants' argument that SCDC was entitled to summary judgment on Eleventh Amendment Immunity grounds, Plaintiffs all subsequently withdrew their § 1983 claims against SCDC. (ECF No. 113 at 4). Plaintiffs, however, urged the court to retain jurisdiction over the state law claims against SCDC. (ECF No. 110 at 18).

         The magistrate judge, after a hearing on the motion, issued a Report finding that Defendants' motion as to the § 1983 claims against SCDC was moot but recommending that the court maintain jurisdiction over Plaintiffs' state law claims against SCDC. (ECF No. 120 at 12). The magistrate judge noted that “even if the Court grants the motion for Partial Summary Judgment in its entirety, federal causes of action will remain against Defendants Warden Reynolds and Warden Joyner” and concluded that “defendants have failed to present any compelling reasons for declining jurisdiction over the state law claims against SCDC.” Id. at 9.

         Defendants filed objections to the Report, arguing that if the court exercises supplemental jurisdiction, Defendants will suffer prejudice from the differing standards of proof that apply to § 1983 claims and claims under the Tort Claims Act. (ECF No. 123 at 4). Specifically, Defendants argue that jurors are likely to be confused by the fact that a mere negligence standard applies to the state law claims against SCDC while a deliberate indifference standard applies to the federal claims against the individual Defendants. Id. at 5. In response, Plaintiffs urge the court to adopt the Report “in full.” (ECF No. 125 at 3). Highlighting the fact that their federal and state claims arise from closely-related factual bases, Plaintiffs argue that no compelling circumstances exist for the court to decline jurisdiction and that any potential confusion can be alleviated by appropriate jury instructions. Id. at 5.

         II. Standard of Review for Report and Recommendation

         “The magistrate makes only a recommendation to this court. The recommendation has no presumptive weight, and the responsibility to make a final determination remains with this court.” Estrada v. Witkowski, 816 F.Supp. 408, 410 (D.S.C. 1993) (citing Mathews v. Weber, 423 U.S. 261, 270-71 (1976)). This Court “shall make a de novo determination of those portions of the report or specified proposed findings or recommendations to which objection is made.” 28 U.S.C. § 636(b)(1). “The filing of objections to a magistrate's report enables the district judge to focus attention on those issues-factual and legal-that are at the heart of the parties' dispute.” Thomas v. Arn, 474 U.S. 140, 147 (1985). “[W]hen a party makes general and conclusory objections that do not direct the court to a specific error in the magistrate's proposed findings and recommendations, ” de novo review is unnecessary. Orpiano v. Johnson, 687 F.2d 44, 47 (4th Cir. 1982) (citations omitted). As recounted above, Defendants filed a specific objection as to the magistrate judge's recommendation that the court continue to exercise jurisdiction over Plaintiffs' state law claims against SCDC. Accordingly, the court will consider that portion of the Report de novo and review the remainder of the Report for clear error.

         III. Discussion

         Section 1367 of Title 28 of the United States Code provides, in pertinent part, as follows:

[I]n any civil action of which the district courts have original jurisdiction, the district courts shall have supplemental jurisdiction over all other claims that are so related to claims in the action within such original jurisdiction that they form part of the same case or ...

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