Opinion

SANCHEZ v. BROWN

Court
District Court, D. New Jersey
Filed
Oct 7, 2025
Cited by
0 cases
Authority
More cited than 35.2%

The opinion

NOT FOR PUBLICATION

UNITED STATES DISTRICT COURT

DISTRICT OF NEW JERSEY

DAVID SANCHEZ,

Plaintiff, Civil Action No. 25-14461 (MAS) (JTQ)

OPINION

SERGEANT A. BROWN, SR., et al.,

Defendants.

SHIPP, District Judge

This matter comes before the Court on Plaintiff David Sanchez’s civil complaint (ECF No.

1) and application to proceed in forma pauperis. (ECF No. 1-1.) Having reviewed the application,

the Court finds that in forma pauperis status is warranted in this matter, and Plaintiffs application

is therefore granted. Because the application shall be granted, the Court is required to screen

Plaintiff’ s complaint pursuant to 28 U.S.C. § 1915(e)(2)(B) and dismiss any claim that is frivolous,

malicious, fails to state a claim for relief, or seeks relief from an immune defendant. For the

reasons set forth below, Plaintiff’s complaint shall be dismissed without prejudice for failure to

state a claim upon which relief may be granted.

I. BACKGROUND

Plaintiff is a state pre-trial detainee currently detained in the Hudson County Correctional

Center. (ECF No. | at 2-3.) Plaintiff arrived at the jail on July 21, 2025. (ECF No. 1-1 at 2.) For

reasons not clearly stated in the complaint, Plaintiff was placed in “medical isolation” upon arrival.

(ECF No. | at 6.) On July 29, however, he was “cleared medically” to leave isolation. Ud.) The

following day, after a court appearance, he spoke with the jail’s chief psychiatrist, who

recommended that Plaintiff be placed in a “drug program tier” based on what Plaintiff describes

as a serious “self-injurious behavior history.” (/d.) Plaintiff does not provide any detail as to that

history. (/d.) The doctor called a Sergeant Estrada in Plaintiff's presence and told the sergeant

that Plaintiff could either be moved to such a tier that day, or could remain in medical housing for

the time being. (U/d.) Plaintiff was thereafter taken back to medical housing until later that night,

when he was moved to a general population unit on the orders of Defendants Brown and Daniels,

who work in the jail’s classification department. (/d.) Plaintiff apparently protested, but was told

that the classification department, rather than the medical department, makes placement decisions

once a prisoner is cleared to leave the medical unit. id.) The two officers who moved Plaintiff,

who are not the named Defendants, told Plaintiff that they “don’t care” 1f Plaintiff hurts himself.

(Id.)

I. LEGAL STANDARD

Because Plaintiff shall be granted in forma pauperis status, the Court is required to screen

his complaint pursuant to 28 U.S.C. § 1915(e)(2)(B). Pursuant to the statute, the Court must sua

sponte dismiss any claim that is frivolous, malicious, fails to state a claim upon which relief may

be granted, or seeks monetary relief from a defendant who is immune from such relief. Jd. “The

legal standard for dismissing a complaint for failure to state a claim pursuant to 28 U.S.C.

§ 1915(e)(2)(B)(ii) is the same as that for dismissing a complaint pursuant to Federal Rule of Civil

Procedure 12(b)(6).” Schreane v. Seana, 506 F. App’x 120, 122 (3d Cir. 2012) (citing Allah y,

Seiverling, 229 F.3d 220, 223 (3d Cir. 2000)).

In deciding a motion to dismiss pursuant to Federal Rule of Civil Procedure 12(b)(6), a

district court is required to accept as true all factual allegations in the complaint and draw all

reasonable inferences from those allegations in the light most favorable to the plaintiff, see Phillips

v. County of Allegheny, 515 F.3d 224, 228 (3d Cir. 2008), but need not accept as true legal

conclusions couched as factual allegations. Papasan y. Allain, 478 U.S. 265, 286 (1986). A

complaint need not contain “detailed factual allegations” to survive a motion to dismiss, but must

contain “more than an unadorned, the-defendant-unlawfully-harmed-me accusation.” Ashcroft v.

Iqbal, 556 U.S. 662, 678 (2009). A complaint “that offers ‘labels and conclusions’ or ‘a formulaic

recitation of the elements of a cause of action will not do,’” and a complaint will not “suffice” if it

provides only “‘naked assertion[s]’ devoid of ‘further factual enhancement.’” /d. (quoting Bell

Atl. v. Twombly, 550 U.S. 544, 555, 557 (2007)). “To survive a motion to dismiss, a complaint

must contain sufficient factual matter, accepted as true, to ‘state a claim to relief that is plausible

on its face.’” /d. (quoting Twombly, 550 U.S. at 570). “A claim has facial plausibility when the

plaintiff pleads factual content that allows the court to draw the reasonable inference that the

defendant is liable for the misconduct alleged.” Jd (quoting Twombly, 550 U.S. at 556). A

complaint that provides facts “merely consistent with” the defendant’s liability “stops short of the

line between possibility and plausibility” and will not survive review under Rule 12(b)(6). /d.

(quoting Twombly, 555 U.S. at 557). While pro se pleadings are to be liberally construed in

conducting such an analysis, pro se litigants must still “allege sufficient facts in their complaints

to support a claim.” Mala v. Crown Bay Marina, Inc., 704 F.3d 239, 245 (3d Cir. 2013).

Ii. DISCUSSION

In his complaint, Plaintiff seeks to raise federal civil rights claims against two members of

the classification committee of the jail in which he is detained for placing him in a general

population unit rather than a “drug program tier” unit after he was cleared to leave medical

isolation. Although pretrial detainees may not be subjected to punishment without a supporting

conviction and may not be placed in restrictive housing without certain procedural protections,

they do not generally have a protected liberty interest in being placed in a specific, non-restrictive

housing unit. See Stevenson v. Carroll, 495 F.3d 62, 68-70 (3d Cir. 2007); see also Brandt v.

Cirillo, No. 22-3752, 2023 WL 157431, at *6 (D.N.J. Jan. 10, 2023) (pretrial detainees do “not

have a protected liberty interest in [a specific] security classification or housing preference”).

Thus, that Plaintiff was placed in the general population, rather than a drug program unit, in and

of itself does not violate Plaintiffs rights and fails to state a plausible claim for relief.

The complaint appears to imply, however, that Plaintiff's placement in the general

population amounts to an infringement of his psychiatric needs based on an unspecified history of

self-harm. A jail official may be held liable under the Fourteenth Amendment where he is

deliberately indifferent to an inmate’s serious medical or psychiatric needs. See Natale v. Camden

Cnty. Corr. Facility, 318 F.3d 575, 582 (3d Cir. 2003). This requires both that the plaintiff show

that he had a sufficiently serious medical need, and that the defendant engaged in actions or

omissions which indicate that the defendant knew of and disregarded “an excessive risk to inmate

health or safety.” Jd. (quoting Farmer v. Brennan, 511 U.S. 825, 837 (1994)). A medical need is

sufficiently serious where it “has been diagnosed as requiring treatment or [is a need that] is so

obvious that a lay person would easily recognize the necessity of a doctor’s attention.” Monmouth

Corr. Inst. Inmates v. Lanzaro, 834 F.2d 326, 347 (3d Cir. 1987), cert denied, 486 U.S. 1006

(1988).

In his complaint, Plaintiff suggests that he may have had a significant psychiatric issue that

caused him to engage in self-harm in the past. Plaintiff provides no details regarding this history,

nor does he allege that self-harm was the reason he was placed in medical isolation. Likewise,

although Plaintiff alleges that the jail’s psychiatrist suggested that he be placed in a drug program

tier, Plaintiff fails to allege any details as to how or why this placement suggestion in any way

serves any medical need related to Plaintiff's alleged history of hurting himself.! Thus, while

Plaintiff suggests he may have psychiatric needs that were recognized by a psychiatric

professional, he does not provide any factual allegations as to how placement in a specific unit is

required by or serves those needs. From the complaint’s allegations, it is at best unclear that even

had Defendants knowingly placed Plaintiff outside a specific unit, that such a placement would

amount to indifference or would ignore Plaintiff's psychiatric needs.

Moving beyond the seriousness of Plaintiffs psychiatric needs, Plaintiffs complaint also

fails to allege facts which permit the inference that the two named Defendants knew of and

disregarded any psychiatric need. Plaintiff alleges that the psychiatrist told Sergeant Estrada, who

is not a named Defendant, that the psychiatrist recommended placement in a drug tier unit.

Plaintiff, however, alleges no facts to suggest that this recommendation was ever communicated

to either Defendant named in the complaint. Likewise, although Plaintiff suggests that the two

unnamed officers who transported him to general population made snide remarks, Plaintiff does

not allege facts clearly demonstrating that these remarks by third parties could be imputed to the

two named Defendants who were not present at the time. Plaintiff has thus failed to adequately

allege facts that would permit an inference that Defendants knew of and disregarded a serious

psychiatric need.” Plaintiffs complaint therefore fails to state a plausible claim for relief and must

be dismissed without prejudice as such.

' The Court presumes that the drug program unit had greater inmate surveillance, but Plaintiff does

not plead this.

* Plaintiff's claim would fare no better if interpreted as a failure to protect claim, which would also

require that he allege facts that would permit the inference that Defendants knew of and

disregarded a serious risk to his safety. See Proctor v. James, 811 F. App’x 125, 128 (3d Cir.

2020) (quoting Bistrian v. Levi, 696 F.3d 352, 367 (3d Cir. 2012)). Plaintiff has not alleged

sufficient facts to suggest the two named Defendants actually knew of any danger he may have

posed to himself and disregarded that risk.

IV. CONCLUSION

For the reasons expressed above, Plaintiffs application to proceed in forma pauperis (ECF

No. 1-1) is GRANTED; and Plaintiff's complaint (ECF No. 1) is DISMISSED WITHOUT

PREJUDICE for failure to state a claim upon which relief may be granted. An order consistent

with this Opinion will be entered.

UNITED STATES DISTRICT JUDGE

Dated: October Th 2025

This is a copy of a public record, reproduced as it was published. It is not legal advice, and it may not be the version a court would rely on. Check the official source before you cite it.

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