Terrell Sims v. Steven Cambell

Summary

The United States District Court for the Central District of Illinois dismissed Terrell Sims's 42 U.S.C. § 1983 complaint under 28 U.S.C. § 1915A for failure to state a federal claim. The court held that the complaint did not allege personal involvement by the named defendant, a constitutional right to a mental-health evaluation before investigative segregation, or a liberty interest in avoiding discretionary segregation. The court granted Sims thirty days to seek leave to file an amended complaint and found his motion for status moot.

Holdings

1. A plaintiff cannot state a § 1983 claim against a defendant merely by naming the defendant in the caption or relying on the defendant's supervisory status; the complaint must allege the defendant's personal responsibility for the constitutional deprivation.
2. The alleged failure to provide a mental-health evaluation before placing an inmate in investigative segregation does not, without more, state a constitutional violation.
3. Inmates have no constitutionally protected liberty interest in avoiding discretionary segregation imposed for administrative, protective, or investigative purposes, absent circumstances that otherwise trigger a protected liberty interest.
4. A complaint that does not plausibly allege a federal constitutional violation or the defendant's personal involvement fails Rule 8(a) and must be dismissed under 28 U.S.C. § 1915A(b)(1).

Questions Presented

1. Whether the complaint stated a plausible § 1983 claim against the former prison warden when it alleged no personal involvement by him.
2. Whether the alleged failure to provide a mental-health evaluation before investigative segregation stated a constitutional claim.
3. Whether Sims had a constitutional liberty interest requiring notice and a hearing before placement in investigative segregation.
4. Whether the complaint satisfied Federal Rule of Civil Procedure 8(a) and the screening requirements of 28 U.S.C. § 1915A.

Disposition

dismissed