David Robert Bentz v. Steven Hall, et al.

Summary

The United States District Court for the Central District of Illinois screened David Robert Bentz’s Third Amended Complaint under 28 U.S.C. § 1915A. The court allowed claims to proceed against certain defendants for First Amendment retaliation, Fourteenth Amendment procedural due process violations, and Eighth Amendment conditions of confinement, while dismissing other defendants and claims without prejudice. The order also addressed service, identification of Doe defendants, discovery, and scheduling matters.

Holdings

1. Bentz stated a First Amendment retaliation claim against Hall because filing lawsuits and grievances is protected activity and the alleged pat-down, threats, harassment, property search, destruction or confiscation of property, and disciplinary ticket plausibly supported retaliatory action.
2. Bentz stated a First Amendment retaliation claim against John Doe #18 based on the allegation that the chairperson threatened to impose and did impose discipline because Bentz said he intended to file a grievance.
3. A prison official cannot be held liable under § 1983 solely because of supervisory status or because the official received correspondence or grievances concerning a subordinate's conduct.
4. Bentz stated a procedural due process claim against Hall and John Doe #18 because the alleged combination of one month of C-Grade, harsh confinement conditions, inadequate notice, and inability to present a defense or call witnesses plausibly implicated a protected liberty interest and denial of required process.
5. Bentz stated an Eighth Amendment conditions-of-confinement claim against Greene, Manton, John Does #2, #6, #7, #9, #10, and #11, and John/Jane Doe #12.
6. Bentz failed to state a First Amendment or § 1983 claim against K. Hasten, D. Hasten, and Wohlfeil based solely on allegedly fabricated grievance records or refusal to process grievances.

Questions Presented

1. Whether Bentz stated a First Amendment retaliation claim against Hall and the adjustment-committee chairperson.
2. Whether Bentz stated a Fourteenth Amendment procedural due process claim based on the disciplinary charge, hearing, and resulting segregation.
3. Whether Bentz stated an Eighth Amendment conditions-of-confinement claim against officials allegedly informed of the conditions and who failed to act.
4. Whether claims against officials based solely on supervisory status or receipt or mishandling of grievances were legally sufficient under § 1983.
5. Whether conclusory allegations against certain defendants were sufficient to survive screening under § 1915A and Rule 12(b)(6).

Disposition

other