David Velazquez-Diaz v. Rachel Young, Karas Correctional Health (KCH); Dr....

United States District Court for the Western District of Arkansas

David Velazquez-Diaz v. Rachel Young, Karas Correctional Health (KCH); Dr....

Trial Court Opinion

IN THE UNITED STATES DISTRICT COURT WESTERN DISTRICT OF ARKANSAS FAYETTEVILLE DIVISION DAVID VELAZQUEZ-DIAZ PLAINTIFF V. CASE NO. 5:24-CV-5212 RACHEL YOUNG, Karas Correctional Health (KCH); DR. ROBERT KARAS, KCH; KELLEY HINELY, KCH; DUSTIN SANDERS, KCH; JORDAN PROVENAS, KCH; JACOB SMOTHERS, KCH; JOHN AND JANE DOE EMPLOYEES OF KCH; and SHERIFF JAY CANTRELL, Washington County, Arkansas DEFENDANTS ORDER Before the Court is the Report and Recommendation (“R&R”) (Doc. 44) filed on November 18, 2025, by the Honorable Christy Comstock, United States Magistrate Judge for the Western District of Arkansas. She recommends that Separate Defendant Sheriff Jay Cantrell’s Motion for Summary Judgment for Failure to Exhaust Administrative Remedies (Doc. 20) be granted. On December 5, 2025, Plaintiff David Velazquez-Diaz filed an Objection to the R&R (Doc. 45), which triggered this Court's de novo review of the record. Mr. Velazquez-Diaz alleges in his Second Amended Complaint (Doc. 8) that six employees of Karas Correctional Health (“KCH”)—a third-party contractor that provides medical care to inmates at the Washington County Detention Center (“WCDC”)—were deliberately indifferent to his medical needs. Separately, he alleges that Defendant Cantrell, in his capacity as administrator of the WCDC, failed to adequately supervise or train jail staff to assure that inmates were receiving adequate medical care and to supervise KCH employees to assure they were providing adequate care. Mr.

Velazquez-Diaz does not allege that Defendant Cantrell personally committed medical neglect. Further, it is undisputed that Mr. Velazquez-Diaz filed several grievances about his medical care through the jail kiosk system, but none of those grievances identified Defendant Cantrell or detention officers by name. Because the WCDC’s grievance process expressly requires an inmate submitting a grievance to “state fully the . . . names of those Detention Officers and/or staff members involved and pertinent details of the incident,” see Doc. 22-4, p. 2, and Mr. Velazquez-Diaz failed to do this with respect to Defendant Cantrell, Judge Comstock believes the claims against Defendant Cantrell are subject to dismissal under the Prison Litigation Reform Act for failure to exhaust administrative remedies prior to filing suit. Mr. Velazquez-Diaz argues in his Objection that Defendant Cantrell, as administrator of the WCDC, “should be responsible for any neglect suffered by the inmates—regardless of . . . his knowledge or [whether he] was not named in any of the grievances or appeals.” (Doc. 45, p. 2). In Mr. Velazquez-Diaz’s view, he has exhausted his remedies with respect to his claims against Defendant Cantrell by filing and appealing medical grievances—which should have been enough to put Defendant Cantrell on notice of his failure to train or supervise the medical personnel. In general, “[clontracting out prison medical care does not relieve the [county] of its constitutional duty to provide adequate medical treatment to those in its custody, and it does not deprive the [county]’s prisoners of the means to vindicate their Eighth Amendment rights.” West v. Atkins,

487 U.S. 42, 56

(1988). However, when a detention center's grievance policy requires an inmate to name each individual involved in the incident being complained of, then that requirement controls for purposes of exhaustion

under the PLRA. See Bums v. Eaton,

752 F.3d 1136, 1141

(8th Cir. 2014). Here, there is no dispute that Mr. Velazquez-Diaz failed to identify Defendant Cantrell or any WCDC jailer by name in any grievance and accuse them of failing to take corrective action with respect to his medical care. A general grievance about the quality of care or disagreement with a treatment decision is not the same thing as identifying a jailer or jail administrator by name for failing to train or supervise a medical professional. The Objection to the R&R is OVERRULED. IT IS THEREFORE ORDERED that the R&R (Doc. 44) is ADOPTED IN ITS ENTIRETY. Defendant Sheriff Jay Cantrell’s Motion for Summary Judgment (Doc. 20) is GRANTED, and Plaintiff's claims against him are DISMISSED WITHOUT PREJUDICE. This case remains referred to the Magistrate Judge. IT IS SO ORDERED on this of oe 2025.

□ _ TIMO WAY L “BROOKS HIEF UNITED STATES DISTRICT JUDGE

Reference

Full Case Name
David Velazquez-Diaz v. Rachel Young, Karas Correctional Health (KCH); Dr. Robert Karas, KCH; Kelley Hinely, KCH; Dustin Sanders, KCH; Jordan Provenas, KCH; Jacob Smothers, KCH; John and Jane Doe Employees of KCH; and Sheriff Jay Cantrell, Washington County, Arkansas
Status
Unknown