# Brown

> District Court, E.D. Arkansas · October 20, 2025

URL: https://www.frixlaw.com/law-library/cases/11174227

## Case

- **Full name:** Iris Brown v. ADC, Medical
- **Court:** District Court, E.D. Arkansas
- **Decided:** October 20, 2025
- **Opinion:** 100trialcourt
- **Cited by:** 0 later opinions in the Frix Law Library

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## Opinion text

IN THE UNITED STATES DISTRICT COURT
EASTERN DISTRICT OF ARKANSAS
NORTHERN DIVISION

IRIS BROWN PLAINTIFF
ADC #709964
V. Case No. 3:25-CV-00125-JM-BBM

ADC, Medical DEFENDANT

ORDER
I. INTRODUCTION
On June 30, 2025, Iris Brown (“Brown”), an inmate currently incarcerated in the
McPherson Unit of the Arkansas Division of Correction (“ADC”), filed a pro se Complaint
pursuant to 42 U.S.C. § 1983, alleging that “ADC, Medical” violated her constitutional
rights. (Doc. 2). Before Brown may proceed with this action, the Court must screen her
claims in accordance with the Prison Litigation Reform Act (“PLRA”).1 28 U.S.C.
§ 1915A(a).
II. ALLEGATIONS
Brown alleges that, on an unspecified date, she told Nurse Hadley Owens
(“Owens”) that her kidney was infected.2 (Doc. 2 at 4). However, the “only thing they did”

1 The PLRA requires federal courts to screen prisoner complaints seeking relief against a
governmental entity, officer, or employee. 28 U.S.C. § 1915A(a). The Court must dismiss a complaint or a
portion thereof if the prisoner has raised claims that: (a) are legally frivolous or malicious; (b) fail to state
a claim upon which relief may be granted; or (c) seek monetary relief from a defendant who is immune
from such relief. Id. § 1915A(b). When making this determination, the Court must accept the truth of the
factual allegations contained in the complaint, and it may consider the documents attached to the complaint.
Ashcroft v. Iqbal, 556 U.S. 662, 678 (2009); Reynolds v. Dormire, 636 F.3d 976, 979 (8th Cir. 2011).

2 Brown writes Nurse Owens’s name as “Nurse Handy.” (Doc. 2 at 4). The Court gathers from her
attached medical records, e.g., id. at 7, 49–50, that Brown is referring to Nurse Owens when she mentions
Nurse Handy.
was tell Brown that her back is hurting “because of the bed.”3 Id. Unnamed staff members
told Brown to “keep putting in sick call[s].” Id. Brown asked “her” for a second opinion,
and “she” told Brown no, but “they” still placed Brown on medication for an infection and

would not do anything else. Id. Brown alleges that now her back is messed up, she cannot
stand very long, and she does not know why “they won’t let me see a doctor.” Id.
Brown attaches several medical records to her Complaint, which appear to be from
a social security administrative record. (Doc. 2 at 4–39, 41–96). Brown does not explain
the purpose of these medical records, but at least some of the records appear related to her

claims of a kidney infection and back pain. See, e.g., id. at 57–59, 62, 69–70.
Brown also attaches grievance documents, variously referencing Nurse Owens,
kidney issues, and the refusal to let Brown see a doctor. (Doc. 2 at 97–112). Brown sues
the Defendant in its official and individual capacity. Id. at 2. She asks the Court to “let
[her] take an MRI or catscan” and requests damages. Id. at 4–5.

III. INITIAL SCREENING
To survive pre-service screening under the PLRA, a “complaint must contain
sufficient factual matter, accepted as true, to state a claim to relief that is plausible on its
face.” Ashcroft v. Iqbal, 556 U.S. 662, 678 (2009). “[L]abels and conclusions,” a
“formulaic recitation of the elements of a cause of action,” and “naked assertions devoid
of further factual enhancement” are insufficient to plead a plausible claim. Id. Further,

3 Throughout this Order, any capitalization, spelling, or grammatical errors are corrected internally
without brackets.
“[f]actual allegations must be enough to raise a right to relief above the speculative level.”
Bell Atl. Corp. v. Twombly, 550 U.S. 544, 555 (2007) (citation omitted).
However, “[a] pro se complaint must be liberally construed,” and courts “should

construe the complaint in a way that permits the layperson’s claim to be considered within
the proper legal framework.” Topchian v. JPMorgan Chase Bank, N.A., 760 F.3d 843, 849
(8th Cir. 2014) (cleaned up; citations omitted); Solomon v. Petray, 795 F.3d 777, 787 (8th
Cir. 2015) (citation omitted). Liberally construing Brown’s Complaint, she fails to allege
any plausible claims against the Defendant, “ADC, Medical.”

A. Official-Capacity Claims
State agencies, such as the ADC, are not “persons” that can be sued under 42 U.S.C.
§ 1983. See Howlett v. Rose, 496 U.S. 356, 365 (1990); McDowell v. Dawson, 221 Fed.
Appx. 497, 498 (8th Cir. 2007) (unpublished) (Missouri Department of Corrections was
not “person” under § 1983); Brown v. Missouri Department of Corrections, 353 F.3d 1038,

1041 (8th Cir. 2004). Additionally, any monetary claim against the ADC is barred by
sovereign immunity. Nix v. Norman, 879 F.2d 429, 432 (8th Cir. 1989).
Brown can bring an official-capacity claim against a proper individual defendant,
and such claim would be considered a claim against the State of Arkansas itself. However,
in order to bring an official-capacity claim, Brown must allege facts showing that any

underlying constitutional violation was the result of an ADC policy, custom, or failure to
train. See Atkinson v. City of Mountain View, Mo., 709 F.3d 1201, 1214 (8th Cir. 2013). As
currently pleaded, Brown makes no such allegations.
B. Deliberate Indifference to Serious Medical Needs
The crux of Brown’s Complaint is that she was denied adequate medical care for
her kidney and back issues. To plead a plausible inadequate-medical-care claim under the

Eighth Amendment, there must be facts suggesting: (1) Brown had an objectively serious
need for medical care; and (2) Defendants subjectively knew of, but deliberately
disregarded, that serious medical need. See Shipp v. Murphy, 9 F.4th 694, 703 (8th Cir.
2021); Barr v. Pearson, 909 F.3d 919, 921 (8th Cir. 2018). As to the second element,
deliberate indifference is a high threshold that goes well beyond negligence or gross

negligence. Hall v. Higgins, 77 F.4th 1171, 1179 (8th Cir. 2023); Langford v. Norris, 614
F.3d 445, 460 (8th Cir. 2010). To establish deliberate indifference, there must be facts
suggesting Defendants “recognized that a substantial risk of harm existed and knew that
their conduct was inappropriate in light of that risk.” Shipp, 9 F.4th at 703 (emphasis in the
original); Smith v. Lisenbe, 73 F.4th 596, 600 (8th Cir. 2023). A mere disagreement with

the course of medical care does not rise to the level of a constitutional violation. Langford,
614 F.3d at 460; Barr, 909 F.3d at 921–22.
Brown asserts that, on an unspecified date, she told Nurse Owens that her kidney
was infected. (Doc. 2 at 4). Her pain was dismissed as relating to her sleeping
arrangements. Id. When Brown asked for a second opinion, she was denied. Id. Yet, Brown

was still provided medication for an infection. Id. Brown’s back continues to hurt, and she
has not been allowed to see a doctor. Id.
There are several deficiencies with these allegations. First, the only person identified
in Brown’s allegations, Nurse Owens, is not a Defendant in this action. But Brown purports
to bring individual-capacity claims. As the Court referenced above, Brown cannot allege
an individual-capacity claim against the ADC; therefore, to state an individual-capacity
claim against any person, Brown must name a person as a Defendant. And, in § 1983

actions, government officials are only liable for their “own individual actions.” Iqbal, 556
U.S. at 676 (emphasis added).
Brown also complains of a kidney infection but admits that she was provided
medication for an infection. (Doc. 2 at 4). As pleaded, an allegation that Brown received
prescription treatment for her alleged illness does not state a deliberate-indifference claim.

Additionally, while Brown asked for a second opinion, and Nurse Owens allegedly
declined, (Doc. 2 at 4), as pleaded, Brown’s mere disagreement with Nurse Owens’s care
does not rise to the level of a constitutional violation. Langford, 614 F.3d at 460; Barr, 909
F.3d at 921–22.
Brown further alleges that her “back is messed up,” (Doc. 2 at 4), but without further

factual enhancement—including dates and times of treatment—it is not entirely clear
whether her back issues are related to the care she received on an unspecified date from
Nurse Owens. Indeed, in the medical records attached to the Complaint, Brown reported
having back problems for years. Id. at 70.
Finally, Brown alleges that she does not know why “they” refuse to let her see a

doctor. (Doc. 2 at 4). It is unclear who “they” are, and it is further unclear when or how
“they” refused to let Brown see a doctor. Additionally, while Brown attached grievance
documents to her Complaint, and the grievance documents reference similar problems to
the allegations in Brown’s Complaint—including kidney issues and refusing to let Brown
see a doctor—the grievances do not shed any light on what exact provider visits Brown
takes issue with. In short, Brown may not simply attach medical records and grievances to
her Complaint and claim that her medical care is constitutionally deficient. She must state

who she takes issue with, what those people did, when the events took place, and why those
actions rise to the level of a constitutional violation. For all of these reasons, Brown fails
to state any plausible deliberate-indifference claim.
IV. OPPORTUNITY TO AMEND
The Court will allow Brown thirty (30) days from the date of this Order to file an

amended complaint to correct the deficiencies in her current pleading. Any amended
complaint must specify the constitutional rights that Brown alleges were violated, list the
Defendants that she believes were personally involved in violating her constitutional rights,
and explain how those Defendants were personally involved. If Brown seeks to state an
official-capacity claim, she must state the basis for doing so.

Brown is placed on notice that, if she files an amended complaint, that pleading will
supersede her previous Complaint. See In re Atlas Lines, Inc., 209 F.3d 1064, 1067 (8th
Cir. 2000). Accordingly, her Amended Complaint should contain all Defendants she seeks
to name in this matter, all claims she seeks to pursue in this action, and the factual predicate
for all claims against all Defendants. If Brown elects not to file an amended complaint, the
Court will proceed to screen her June 30, 2025 Complaint, (Doc. 2).
V. CONCLUSION
IT IS THEREFORE ORDERED THAT:
1. The Clerk is directed to mail Brown a § 1983 complaint form that is labeled
“Amended Complaint.”
2. Brown will be allowed to file, within thirty (30) days of the date of this
Order, an Amended Complaint containing the facts described in this Order, which are
necessary to support her claims. If she elects not to file a timely Amended Complaint, the
Court will screen her original Complaint.
SO ORDERED this 20th day of October, 2025.

UNITED STATES MAGISTRATE JUDGE

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Source: Frix Law Library, https://www.frixlaw.com/law-library/cases/11174227. Public record. Not legal advice.