Charles Flynn v. Steven Campbell, et al.

Summary

The court screened Charles Flynn’s amended complaint alleging that Illinois prison officials violated his Fourteenth Amendment due process rights in handling his requests for protective custody and related classification decisions. The court dismissed the complaint without prejudice for failure to state a claim but granted Flynn 28 days to seek leave to amend with a proposed amended complaint.

Holdings

1. An inmate generally has no protected liberty interest in being housed at a particular correctional facility or in receiving a particular classification level or placement, unless the challenged conditions impose an atypical and significant hardship in relation to the ordinary incidents of prison life.
2. A violation of state law or state administrative regulations, standing alone, is not a basis for a federal civil-rights claim.
3. The amended complaint failed to state a plausible Fourteenth Amendment due-process claim and was subject to dismissal without prejudice under 28 U.S.C. § 1915A.

Questions Presented

1. Whether an inmate has a protected liberty interest in a particular correctional facility, classification level, or prison placement for purposes of a Fourteenth Amendment due-process claim.
2. Whether alleged violations of Illinois statutes or prison regulations, without more, establish a federal civil-rights claim.
3. Whether the amended complaint stated a plausible federal due-process claim under the Prison Litigation Reform Act screening standard.

Disposition

dismissed