United States District Court, M.D. Georgia, Macon Division
T. TREADWELL, JUDGE UNITED STATES DISTRICT COURT.
Jeremy Jay Woody alleges a Fourteenth Amendment
over-detention claim. He states he was wrongfully
incarcerated for seventy-two days past his maximum release
date. Doc. 18 at 1. The Defendants move to dismiss
Woody's action for failure to state a claim. Doc. 29.
They argue that (1) Woody has failed to allege facts showing
any Defendant was subjectively aware of the over-detention,
Doc. 29-1 at 5-10; (2) he has failed to state a claim for
supervisory liability against Sonya Holland and Kenneth
Mantle, Doc. 29-1 at 10-13; and (3) all Defendants are
entitled to qualified immunity, Doc. 29-1 at 13-17. The
Defendants' motion to dismiss is denied.
FACTUAL AND PROCEDURAL BACKGROUND
is deaf and communicates using American Sign Language
(“ASL”). Doc. 18 at 1-2. He does not speak and is
unable to “read lips.” Id. at 2. While
Woody can communicate simple information in written English,
he requires an interpreter to effectively communicate with
others who are not proficient in ASL. Id.
re-entered the Georgia Department of Corrections'
(“GDOC”) custody in August 2013. Id. at
1. GDOC officials informed him that his maximum release date
was October 7, 2017. Id. at 3. This was incorrect.
Id. GDOC officials failed to give Woody credit for
the time he spent in county jail. Id. at 1.
Woody's correct maximum release date was June 7, 2017.
August 18, 2017, GDOC apparently discovered its error and
notified Woody, via a handwritten note, that he was being
released that day. Id. at 4. Woody, who had received
no preparation for release or re-entry planning, requested a
bus ticket to Atlanta because he had family and friends
there. Id. at 1, 4. The bus to Atlanta had already
departed for the day, so officers placed him on a bus headed
to Athens, Georgia. Id. at 4. Woody knew no one in
Athens, had no housing in place, and had no identification
with him. Id. at 5. Woody ended up homeless in
Athens, Georgia. Id. at 4.
alleges he did not learn that he was incarcerated beyond his
maximum release date until 2018 when he commenced discovery
in a separate action, Woody v. Bryson,
5:16-cv-467-MTT (M.D. Ga.). Id. at 1-2.
alleges that Defendants Donna Spires, Winnie Colbert, Sonya
Holland, and Kenneth Mantle are all current or former
employees of Offender Administration, which is the GDOC
department responsible for ensuring that inmates are not
detained beyond their maximum release date. Id. at
2-3, 5-6. Mantle is the Manager of Offender Administration.
Id. at 3, 6. Spires is the Jail Coordinator who
determined a maximum release date for Woody on August 14,
2013. Id. at 3, 5. Colbert, who is currently retired
from GDOC, determined a maximum release date for him on May
6, 2009. Id. Holland, who is the Offender Processing
Manager in Offender Administration, had the responsibility
for ensuring that Woody was given credit for the time he
spent in the county jail. Id. Woody alleges that
Spires, Colbert, and Holland “were plainly incompetent,
and acted maliciously, intentionally, and in reckless
disregard with deliberate indifference to . . . Woody's
constitutional rights.” Id. at 7.
alleges that his over-detention and emergency release were
not isolated occurrences. Id. at 7. Instead, he
states there have been numerous over-detentions in recent
years due the Offender Administrations' sentence
computation errors. Id. According to Woody,
Defendants Holland and Mantle were on notice of a pattern of
over-detention but failed to intervene and failed to train
and supervise the employees responsible for calculating
inmates' sentences. Id. at 7-8. Woody alleges
that Holland and Mantle have, with deliberate indifference,
maintained “an unlawful policy or custom of imposing
unlawful detention through sentence miscalculations and the
failure to correct such miscalculations.” Id.
seeks damages. Woody was not incarcerated at the time he
filed this action. The Prison Litigation Reform Act,
therefore, does not apply.
move under Fed.R.Civ.P. 12(b)(6) to dismiss Woody's first
Standard of Review
Federal Rules of Civil Procedure require that a pleading
contain “a short and plain statement of the claim
showing that the pleader is entitled to relief.”
Fed.R.Civ.P. 8(a)(2). To avoid dismissal pursuant to
Fed.R.Civ.P. 12(b)(6), a complaint must contain sufficient
factual matter to “‘state a claim to relief that
is plausible on its face.'” Ashcroft v.
Iqbal, 556 U.S. 662, 678 (2009) (quoting Bell Atl.
Corp. v. Twombly, 550 U.S. 544, 570 (2007)). “At
the motion to dismiss stage, all well-pleaded facts are
accepted as true, and the reasonable inferences therefrom are
construed in the light most favorable to the
plaintiff.” Garfield v. NDC Health Corp., 466
F.3d 1255, 1261 (11th Cir. 2006) (internal quotation marks
and citation omitted).
there are “enough fact[s] to raise a reasonable
expectation that discovery will reveal evidence” to
support the claims alleged in the complaint, the claims are
“plausible” and the motion to dismiss should be
denied and discovery commenced. Twombly, 550 U.S. at
556. However, “where the well-pleaded facts do not
permit the court to infer more than the mere possibility of
misconduct, the complaint has alleged- but it has not
‘show[n]'-‘that the pleader is entitled to
relief.'” Iqbal, 556 U.S. at 679 (quoting
Fed.R.Civ.P. 8(a)(2)). “[C]onclusory allegations,
unwarranted deductions of facts or legal conclusions
masquerading as facts will not prevent dismissal.”
Oxford Asset Mgmt., Ltd. v. Jaharis, 297 F.3d 1182,
1188 (11th Cir. 2002) (citations omitted). The complaint must
“give the defendant fair notice of what the . . . claim
is and the grounds upon which it rests.”
Twombly, 550 ...