Legal Aid Center of Southern Nevada Voulentters

Plaintiff, who is a prisoner in the custody of the Nevada department of corrections (“NDOC”), has submitted a civil rights complaint pursuant to 42 U.S.C. § 1983.  In the complaint, plaintiff sues multiple defendants for events that took place while plaintiff was incarcerated as a pretrial detainee at the Clark County Detention Center (“CCDC”). In count I, plaintiff alleges the following: classified plaintiff, a pretrial detainee, as “max status” to punish plaintiff. Under this classification, jail officials confined plaintiff to his cell for 23 hours a day on the weekdays and 48 hours for the weekends, denied plaintiff all programs, restricted plaintiff’s television viewing options, restricted visitation, and restricted commissary. Plaintiff had been in solitary maximum lock up for over 730 days. Two prison officials mailed plaintiff a letter sanctioning plaintiff to 60 days confinement which prohibited commissary and visitation. (Id.) This sanction caused extreme hardship because jail officials did not serve enough food to properly feed the inmates. (Id. at 23, 28). The officials sanction caused plaintiff to lose 70 pounds. (Id. at 28). Another officer also allegedly came into plaintiff’s cell and sexually assault plaintiff. (ECF No. 1 at 24). Officers slammed plaintiff backwards and injured plaintiff’s neck and head. (Id.) After plaintiff hit the concrete in handcuffs, the officers rolled plaintiff onto his back and stood on his back. In the meantime, plaintiff was suffocating from the officers on his back. (Id. at 42). After plaintiff returned to consciousness from the lack of air, the officer put a tazer in plaintiff’s mouth. When the officers stopped, plaintiff’s boxers were pulled down to his knees and the officers laughed at plaintiff as they walked away. (Id.) Plaintiff went into convulsions.

Plaintiff sues multiple defendants for events that occurred at High Desert State Prison (“HDSP”). On October 2013, client received a threat of bodily harm him from another inmate.  Plaintiff reported the threat to his unit (7 A/B) floor officer. On October 24, 2013, plaintiff participated in a “full classification committee” (“FCC”) meeting. (Id.). This FCC meeting was conducted by caseworker supervisor C. Leavitt with warden Neven in attendance. (Id.). At this meeting, plaintiff completed a “central monitoring system” (“CMS”) form which listed inmate as being added to plaintiff’s “enemy list.” (Id.). The effect of this form is to alert prison officials that plaintiff seeks protection from harm at the hands of this inmate . Plaintiff was led to believe that this inmate would be moved from unit 7/8 and plaintiff would be safely moved back in. (Id.).On the morning of February 11, 2014, plaintiff was staged with other inmates in the unit
7/8 yard, waiting for an escort to the education building. (Id. at 5). The inmate made an unauthorized exit from his cell into the yard. (Id.). John Does II and III are both responsible for this unauthorized exit. (Id.). Inmate  attacked plaintiff with stones, gravel, and his fists. (Id.). Plaintiff suffered various injuries, including a broken nose. (Id.). One of the supervisors  responded to the yard when this incident occurred. (Id.). As a result of the attack, plaintiff suffered extreme physical, emotional, and mental pain. (Id.).