US District Court WDVA Docket Feed

Reed v. Zook — Prisoner Hygiene Items Claim Dismissed Under Eighth Amendment

The U.S. District Court for the Western District of Virginia dismissed pro se inmate Winston Najee Reed's 42 U.S.C. § 1983 civil rights action against Warden Zook et al. with prejudice. Reed alleged that prison officials violated his Eighth and First Amendment rights by denying him a hygiene pack—including a toothbrush, deodorant, and cleaning supplies—for eight days upon arrival at Wallens Ridge State Prison from May 20–28, 2025. Applying the Farmer two-part test for Eighth Amendment claims (objective seriousness and deliberate indifference), the court held that a temporary deprivation of toiletries does not constitute cruel and unusual punishment, citing prior circuit precedent holding that denial of hygiene products for comparable periods does not meet the threshold. The court further rejected Reed's First Amendment free exercise claim, finding that an eight-day deprivation of hygiene items does not impose a "substantial burden" on religious practice. The complaint was dismissed under 28 U.S.C. § 1997e(c)(1) for failure to state a cognizable claim.

Abdul Mu'min v. Mrs. C. D. Cook — Motion for Reconsideration Denied

The United States District Court for the Western District of Virginia denied pro se inmate Abdul Mu'min's Motion for Reconsideration on April 22, 2026, affirming its November 6, 2025 dismissal of his 42 U.S.C. § 1983 civil rights action without prejudice. The court held that Mu'min failed to satisfy any of the three grounds for Rule 59(e) relief and further found he is a 'three-striker' under the Prison Litigation Reform Act, having had three or more prior actions dismissed as frivolous, malicious, or for failure to state a claim, thereby precluding in forma pauperis status under 28 U.S.C. § 1915(g). The court also noted that Mu'min attempted to circumvent PLRA payment requirements by scratching out provisions on consent forms.

Campbell Stay Motion Denied, Sanctions Rejected

The US District Court for the Western District of Virginia denied two motions in the bankruptcy appeal of Kathy Jean Campbell v. Julie A. Garrett (Case No. 3:25-cv-00050). The court denied Campbell's motion for stay pending appeal because she sought relief without posting a bond and failed to demonstrate likelihood of success on the merits, irreparable harm, or that the balance of equities favored a stay under Rule 8025 and Rule 62. The court also denied Garrett's motion for summary disposition and sanctions as premature, with the ruling issued on April 22, 2026.