Marquis Kinnel v. Commissioner Quiros, et al.

Summary

The United States District Court for the District of Connecticut conducted an initial review of Marquis Kinnel’s 42 U.S.C. § 1983 claims arising from prison disciplinary proceedings and a cell search. The court dismissed the federal claims without prejudice, concluding that the complaint failed to establish personal involvement, a cognizable due process violation, an Eighth Amendment violation, or facts supporting conspiracy. The court declined supplemental jurisdiction over state-law claims and granted Kinnel one opportunity to amend.

Holdings

1. A plaintiff seeking damages under § 1983 must allege facts establishing each defendant's personal involvement in the asserted constitutional violation, including supervisory officials. Because the complaint alleged no conduct by Commissioner Quiros, Warden Guardarrama, or Nick Rodriguez connecting them to the violations, the damages claims against them were dismissed without prejudice.
2. An inmate has no general constitutional right to be free from being falsely accused in a misbehavior report; therefore, any due process claim based solely on allegedly false disciplinary charges was dismissed.
3. A § 1983 procedural due process challenge to prison disciplinary proceedings is barred when success would necessarily imply the invalidity of a deprivation affecting the duration of confinement, unless the underlying sanction has been invalidated or the prisoner waives for all time any challenge to that sanction.
4. The alleged sanctions, excluding the forfeiture of Risk Reduction Earned Credit days, did not plausibly constitute an atypical and significant hardship in relation to the ordinary incidents of prison life; therefore, Plaintiff did not allege a cognizable liberty interest supporting procedural due process protection.
5. Conclusory allegations that Plaintiff was subjected to cruel and unusual punishment, without facts showing excessive force or deliberate indifference to health or safety, failed to state an Eighth Amendment claim.
6. A § 1983 conspiracy claim requires factual allegations suggesting that the defendants reached an express or tacit agreement to achieve an unlawful end; conclusory, vague, or general allegations are insufficient.
7. After dismissing all federal claims, the court declined to exercise supplemental jurisdiction over Plaintiff's state-law claims under 28 U.S.C. § 1367(c)(3).

Questions Presented

1. Whether the complaint plausibly alleged personal involvement by Commissioner Quiros, Warden Guardarrama, and District Administrator Nick Rodriguez sufficient to support § 1983 damages claims.
2. Whether Plaintiff's procedural due process claims concerning prison disciplinary proceedings were barred by Heck v. Humphrey and Peralta v. Vasquez because the proceedings resulted in forfeiture of sentence-related credits.
3. Whether, apart from the sentence-credit forfeiture, the disciplinary sanctions alleged an atypical and significant hardship creating a protected liberty interest.
4. Whether allegations that Defendants issued allegedly false disciplinary reports stated a constitutional due process claim.
5. Whether the complaint plausibly alleged an Eighth Amendment excessive-force or deliberate-indifference claim.
6. Whether the complaint plausibly alleged a conspiracy to violate Plaintiff's constitutional rights.
7. Whether the court should exercise supplemental jurisdiction over Plaintiff's state-law claims after dismissing the federal claims.

Disposition

dismissed