Strickland v. Sumner County Jail

Full title: JASON R. STRICKLAND Plaintiff, v. SUMNER COUNTY JAIL Defendant

Court: United States District Court, M.D. Tennessee, Nashville Division

Case No. 3:11-0441.

Date published: Jun 27, 2011

Fact:

The plaintiff, an inmate at the Sumner County Jail in Gallatin, Tennessee, filed a pro se action under 42 U.S.C. § 1983 against the Sumner County Jail. The plaintiff alleged that jail personnel were coercing religious beliefs upon him and other inmates, challenging the conditions of his confinement.

Issue:

The main issue is whether the plaintiff’s complaint, although technically against an entity (Sumner County Jail) that is not considered a “person” under § 1983, can be construed as stating a potential claim against Sumner County for coerced religious teaching, thereby presenting a claim upon which relief can be granted under the First Amendment.

Decision:

The court granted the plaintiff’s application to proceed in forma pauperis and found that the complaint, despite its technical deficiency in naming a non-person entity, stated a potential claim against Sumner County for coerced religious teaching. The court concluded that the complaint raised a potential claim upon which relief could be granted under the First Amendment. The clerk was directed to issue process, and a copy of the order was sent to the Sheriff of Sumner County to ensure compliance with the Prison Litigation Reform Act regarding the payment of the filing fee.

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