Prisons – District court did not err when it construed inmate’s pro se complaint

Where the district court construed an inmate’s pro se complaint as asserting a claim for deliberate indifference, and dismissed that claim, the appellate court rejected his argument that he was also asserting a claim under the Americans with Disabilities Act. His “essential grievance” is that two medical professionals were deliberately indifferent to his serious medical needs in violation of the Eighth Amendment.

Background

While Daniel Jackson was an inmate at the Augusta Correctional Center in Craigsville, Virginia, he filed a pro se form complaint against Augusta’s medical department and two individual healthcare providers at Augusta, Dr. Kyle Smith and Nurse Derinda Dameron.

Under 28 U.S.C. § 1915A, the district court screened Jackson’s complaint. It construed Jackson’s complaint to assert claims against Smith and Dameron for deliberate indifference to his serious medical needs in violation of the Eighth Amendment. It dismissed Augusta’s medical department as an improper defendant.

Jackson then moved to file a supplemental complaint. He maintained that his pleadings “clearly f[e]ll under the Eighth Amendment[] and [met] the standards for serious medical need and Deliberate indifference on the part of the Defendants.” After the court accepted the supplemental complaint, the defendants moved to dismiss the claims against Dameron and for summary judgment on all claims.

When addressing the motion to dismiss, as before, the district court understood Jackson’s complaint to assert a deliberate indifference claim. And based on Jackson’s new allegations, the district court also acknowledged a First Amendment retaliation claim premised on Dameron’s actions after he sued.

The district court dismissed Jackson’s First Amendment claim against Dameron, and granted defendants’ motion for summary judgment on Jackson’s deliberate indifference claims.

Analysis

Jackson does not challenge the district court’s resolution of his deliberate indifference claims or his retaliation claim. Instead, for the first time, he faults the district court for not recognizing an additional claim—a failure to accommodate claim under the Americans with Disabilities Act, or ADA—in his original complaint.

It is true that Title II of the ADA prohibits state prisons from discriminating against disabled inmates on account of their disability. It is also true that disability discrimination in prisons includes failing to provide reasonable accommodations to inmates with disabilities. And finally, with the benefit of hindsight, it is true that one could possibly imagine an ADA claim in Jackson’s allegations about having to climb two flights of stairs and wanting a medical boot exemption for work.

But those truths do not mean the district court erred. The thrust of Jackson’s complaint, its essential grievance, was deliberate indifference. He alleged that he had a serious medical condition in the form of his lower body troubles. And his allegations focused on Smith’s and Dameron’s disregard of that condition and the risks it posed to Jackson.

Jackson’s “essential grievance” is that Smith and Dameron were deliberately indifferent to his serious medical needs in violation of the Eighth Amendment. They indicate that Jackson felt the defendants knew of his condition and needs but, over and over, consciously disregarded them.

Our colleague in dissent contends that an ADA claim was just as much of an “essential grievance” as an Eighth Amendment deprivation of serious medical needs claim. In explaining this view, he points out that the legal issues for ADA claims are similar to those for Eighth Amendment disregard of serious medical needs claims. Despite those similarities, Jackson’s factual assertions are almost exclusively aimed at Smith and Dameron’s awareness of his medical needs and their conscious disregard towards them.

Notably, in his response to the defendants’ waiver of answers to his supplemental complaint, Jackson reemphasized his claims were for deliberate indifference. What’s more, Jackson asserted an additional claim, based on an alleged campaign of retaliation, in his supplemental complaint. This suggests that he was capable of alleging additional claims, like ADA claims, if he had so desired.

Affirmed.

Dissenting opinion

Floyd, J., dissenting:

I would reverse the district court’s first order to dismiss for failing to identify that Jackson’s initial pro se complaint alleged causes of action for both deliberate indifference as to Jackson’s serious medical needs in violation of the Eighth Amendment and relief under the ADA. The lower court erred when it solely construed the complaint as bringing a § 1983 claim for Eighth Amendment deliberate indifference to medical needs. The complaint no more expressly invoked the constitutional right than the statutory right as the legal basis for the relief claimed. Because the majority holds otherwise, I respectfully dissent.

Jackson v. Dameron, Case No. 25-6295, March 30, 2026. 4th Cir. (Quattlebaum), from WDVA at Roanoke (Urbanski). Samuel David Kinder Weiss for Appellant. Nathan Henry Schnetzler for Appellees. VLW 026-2-108. 40 pp.

Full-Text Opinion

VLW 026-2-108
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