A lawsuit filed in federal court alleges that correctional staff and healthcare providers at a county jail failed to protect an incarcerated individual with a known seizure disorder, resulting in repeated injuries. The complaint claims that the failure to provide appropriate medical care and housing accommodations led to serious harm for the plaintiff.
The civil action was brought by Rodney Watts on March 20, 2026, in the United States District Court for the District of New Jersey against the County of Mercer, Mercer County Correctional Center, CFG Healthcare, Charles Ellis, Nancy Gordon, Henrietta Ukaegbu, Lieutenant Chad Frascella, and unnamed individuals identified as John and Jane Does #1-10.
According to the complaint, Rodney Watts was arrested around February 2024 and placed in the general population at Mercer County Correctional Center (MCCC). The filing states that defendants were aware of Watts’s history of seizures from previous admissions dating back to August 2022. At that time, records indicated he required seizure precautions such as a bottom bunk pass. However, the complaint alleges that in April 2023 defendants determined unilaterally that Watts did not meet qualifications for a lower bunk pass without evaluation by a neurologist or other qualified professional.
Upon intake at MCCC following his most recent arrest, Watts reportedly informed correctional officials about his need for Depakote or other anti-seizure medications. Despite this notice and repeated requests for safer housing arrangements due to his condition, defendants allegedly refused or ignored these requests. The lawsuit details several incidents where Watts suffered seizures while assigned to an upper bunk: on March 25, 2024 he fell from his top bunk during a seizure and sustained facial lacerations and a large hematoma; on September 19, 2024 he experienced another seizure with severe pain after falling; and on November 27, 2024 he suffered additional lacerations during yet another seizure-related fall.
The complaint asserts that after these incidents some staff members attributed Watts’s falls to drug use rather than his documented medical condition. Specifically, it is alleged that Defendant Nancy Gordon documented after the March incident that Watts “got high on the unit” and “was smoking some substance,” while both Gordon and Henrietta Ukaegbu made similar notes following the November incident. The suit states there was no contemporaneous drug test conducted to corroborate these characterizations. It further alleges this pattern of attributing falls to drug use occurred in coordination with Defendant Sergeant Frascella who had authority over housing assignments.
Watts contends that this consistent mischaracterization minimized or disregarded his medical needs and contributed significantly to delays in providing him with an appropriate bottom bunk pass. According to the filing: “The continued refusal and/or ignoring of the requests for the lower bunk in view of the known serious medical condition… demonstrates deliberate indifference.”
The lawsuit also claims defendants failed to provide necessary medications at times which may have contributed directly to some of his seizures. It further outlines alleged failures including lack of supervision or monitoring despite knowledge of risk factors; failing to refer Watts for proper medical evaluations; leaving him unattended for long periods; failing to provide timely treatment; and generally acting with what is described as “deliberate indifference” toward his health and safety.
As a result of these actions or omissions by correctional staff and healthcare providers—acting under color of state law—the plaintiff alleges violations of rights guaranteed by the Fourteenth Amendment under federal civil rights law (42 U.S.C. §1983). He asserts he suffered physical injuries including wounds on his forehead and arms as well as pain, mental anguish, humiliation, and embarrassment.
Rodney Watts seeks judgment against all named defendants individually or jointly for damages exceeding $150,000 exclusive of interest and costs. He requests recovery for damages under federal law as well as any other relief deemed necessary by the court.
The case was filed by attorney Kaitlin C. McCaffrey of van der Veen, Hartshorn & Levin on behalf of Rodney Watts under case number 3:26-cv-02914.
Source: 326cv02914_Watts_v_County_of_Mercer_Complaint_District_New_Jersey.pdf
