Lucas v. Chalk

Lambda Legal, Just Detention International (JDI), and the Center for Constitutional Rights (CCR) filed a friend-of-the-court brief on behalf of Chase Edward Lucas urging the Sixth Circuit Court of Appeals to reverse a district court’s judgment that dismissed Lucas’s complaint alleging denial of medical care and discriminatory treatment because of his sexual orientation. Under the Prison Litigation Reform Act (“PLRA”) the district court dismissed the complaint at the screening stage for failure to state a claim and certified that an appeal would not be taken in good faith.

Chase Edward Lucas, a bisexual man in the Tennessee Department of Correction’s (TDOC) custody reported that he had been raped twice while in TDOC custody. Lucas sought counseling for anxiety caused by the rapes.  In his complaint, Lucas alleges that Allen Chalk, the prison’s Mental Health Coordinator, said that he believed Lucas was lying because his case had been dismissed as “unsubstantiated” due to lack of evidence. Chalk also allegedly said that because Lucas was bisexual, he “probably liked it.” Lucas filed suit alleging violations of the Eighth Amendment, 42 U.S.C. § 1983, and the Prison Rape Elimination Act (PREA).

At the screening stage, the district court dismissed the Lucas complaint for failing to state a claim and concluded that an appeal would not be taken in good faith (a finding that gave Lucas a “strike” under the in forma pauperis statute).  The district court did not give Lucas an opportunity to amend his complaint.

The brief documents that lesbian, gay, bisexual, and transgender (“LGBT”) people are disproportionately incarcerated and are at a greater risk of sexual assault from both other inmates and staff while incarcerated. In 2003, Congress enacted the Prison Rape Elimination Act (“PREA”) to set national standards addressing sexual abuse in the United States’ systems of incarceration. The National Standards to Prevent, Detect, and Respond to Prison Rape, recognize that LGBT people experience a heightened risk of sexual assault and require mental health care for all sexual assault victims. The brief also explains that district courts must engage in meaningful review of complaints filed by pro se prisoners, under the PLRA, while applying a less stringent pleading standard to pro se plaintiffs.