Chad Langford v. Hector Joyner, No. 21-7737 (4th Cir. 2023)
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On March 20, Plaintiff, an inmate, experienced abdominal pain, nausea, and vomiting. He was transported to an outside hospital for evaluation and testing. The results were deemed “unremarkable,” and Plaintiff was returned to his home institution. Ultimately, Plaintiff was diagnosed with an abdominal infection due to a small bowel obstruction and alleged permanent injury.
Plaintiff brought a claim of deliberate indifference against various prison officials ("Defendants"). The district court dismisses Plaintiff's claim under 12(b)(6). Defendants argued that Plaintiff's “generalized, conclusory, and collective allegations” fail to plausibly allege deliberate indifference on the part of each Defendant.
The Fourth Circuit affirmed. Plaintiff's complaint made collective allegations against all “Defendants,” without identifying how each individual Defendant personally interacted with Langford or was responsible for the denial of his Eighth Amendment rights.
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