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Delaware Federal Court Examines Legal Requirements For § 1983 Claims Against Correctional Officers

Jermaine L. Carter v. Robert Coupe, et al.
Case No. 15-1100-SLR (United States District Court for the District of Delaware, February 8, 2016)
by Richard J. Medoff, Associate
Semmes, Bowen & Semmes (www.semmes.com)

Available at: www.ded.uscourts.gov/sites/default/files/opinions/slr/2016/february/15-1100.pdf

Jermaine L. Carter v. Robert Coupe, et al. involved a civil rights lawsuit filed by a Delaware inmate against several correctional officers, pursuant to 42 U.S.C. § 1983, alleging that he was served false disciplinary reports which caused him to serve disciplinary sanctions. The United States District Court for the District of Delaware explained that the filing of a false disciplinary charge does not constitute a claim under § 1983 so long as the inmate was granted a hearing and an opportunity to rebut the charges. The Court found that the inmate had been provided with disciplinary hearings in this case; and thus, the Court dismissed the inmate’s lawsuit as legally frivolous pursuant to the screening provisions of 28 U.S.C. §§ 1915(e)(2)(B)(i) and 1915(A)(b)(1).

By way of factual background, Plaintiff Jermaine L. Carter ("Plaintiff"), an inmate at the James T. Vaughn Correctional Center (“JTVCC”), filed a civil rights lawsuit in the United States District Court for the District of Delaware against several JTVCC staff members (collectively, “Defendants”), pursuant to 42 U.S.C. § 1983. Plaintiff proceeded pro se and had been granted in forma pauperis status. In his complaint, Plaintiff alleged that he was served false disciplinary reports which caused him to serve disciplinary sanctions. Specifically, Plaintiff alleged that the disciplinary reports "show no witnesses listed as N/A not available [and] show no evidence to support the allegations in [the] falsified disciplinary report write-ups." Prior to filing the complaint, Plaintiff had pled "not guilty" at his JTVCC preliminary disciplinary hearings and "not guilty" at his regular disciplinary hearings, with no help from the JTVCC disciplinary appeal process. Plaintiff also complained that no disciplinary investigations were conducted before recommendations were made for him to serve disciplinary sanctions. Plaintiff sought injunctive relief to change the disciplinary report process and expungement of his record, as well as compensatory damages.

The Court began its analysis by noting that a federal court may properly dismiss an action sua sponte under the screening provisions of 28 U.S.C. §§ 1915(e)(2)(8) and 1915A(b) (the “screening provisions”) if "the action is frivolous or malicious, fails to state a claim upon which relief may be granted, or seeks monetary relief from a defendant who is immune from such relief." See Ball v. Famiglio, 726 F.3d 448, 452 (3d Cir. 2013); see also 28 U.S.C. § 1915(e)(2) (in forma pauperis actions); 28 U.S.C. § 1915A (actions in which prisoner seeks redress from a governmental defendant); 42 U.S.C. § 1997e (prisoner actions brought with respect to prison conditions).

The Court explained that an action is frivolous if it "lacks an arguable basis either in law or in fact," and that a court may dismiss a complaint as frivolous if it is "based on an indisputably meritless legal theory" or a "clearly baseless" or "fantastic or delusional" factual scenario. See Neitzke v. Williams, 490 U.S. 319, 325-28 (1989); Wilson v. Rackmill, 878 F.2d 772, 774 (3d Cir. 1989); Deutsch v. U.S., 67 F.3d 1080, 1091-92 (3d Cir. 1995) (holding frivolous a suit alleging that prison officials took an inmate's pen and refused to give it back). The Court further explained that the legal standard for dismissing a complaint for failure to state a claim pursuant to the screening provisions is identical to the legal standard used when ruling on Rule 12(b)(6) motions. See Tourscherv. McCullough, 184 F.3d 236, 240 (3d Cir. 1999) (applying Fed. R. Civ. P. 12(b)(6) standard to dismissal for failure to state a claim under § 1915(e)(2)(B)).

Turning to the facts of the case, the Court noted that the filing of a false disciplinary charge does not constitute a claim under § 1983 so long as the inmate was granted a hearing and an opportunity to rebut the charges. See Crosby v. Piazza, 465 F.App'x 168, 172 (3d Cir. 2012) (unpublished) (citing Smith v. Mensinger, 293 F.3d 641, 653-54 (3d Cir. 2002)). The Court further noted that there were no allegations that Plaintiff was denied a hearing. To the contrary, the Court found that it was clear from the allegations that Plaintiff was provided with preliminary hearings, regular disciplinary hearings, and that he appealed the findings.

In addition, the Court noted that the “failure to investigate” claim fails as a matter of law because Defendants had no mandatory duty to investigate prior to recommending that Plaintiff serve disciplinary sanctions. See e.g., Ali v. Kasprenski, 732 F.Supp.2d 439, 445 (D. Del. 2010) (no duty of supervisor to investigate incident report prepared by correctional officer); Schaeffer v. Wilson, 240 F.App'x 974, 976 (3d Cir. 2007) (unpublished) (no mandatory duty to investigate and pursue the prosecution of inmates and officers).

For the above reasons, the Court dismissed Plaintiff’s lawsuit as legally frivolous, pursuant to 28 U.S.C. §§ 1915(e)(2)(B)(i) and 1915(A)(b)(1).