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Woody v. Spires

United States District Court, M.D. Georgia, Macon Division

June 13, 2019




         Plaintiff 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.


         Woody 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.

         Woody re-entered[1] 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. Id.

         On 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.

         Woody 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.

         Woody 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.

         Woody 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. at 8.

         Woody seeks damages.[2] Woody was not incarcerated at the time he filed this action. The Prison Litigation Reform Act, therefore, does not apply.

         Defendants move under Fed.R.Civ.P. 12(b)(6) to dismiss Woody's first amended complaint.


         A. Standard of Review

         The 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).

         If 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 ...

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