Jacob S. Davis v. Rebecca Strauss, Pasley S. Holmes, Kristina Perales, and Kristin Sepeda

Summary

The United States District Court for the District of Idaho conducts initial screening of Jacob S. Davis’s amended prisoner civil-rights complaint under 28 U.S.C. §§ 1915(e)(2)(B) and 1915A. The court permits access-to-courts claims against prison officials Holmes and Sepeda concerning interference with Davis’s state post-conviction proceedings, but rejects claims concerning an Arizona conditions-of-confinement lawsuit, a pardon application, alleged retaliation, and violations of state law or prison policies. The court also denies Davis’s motion for a preliminary injunction.

Holdings

1. Davis plausibly stated access-to-courts claims against Holmes and Sepeda because he alleged that they prevented him from submitting evidence supporting a nonfrivolous actual-innocence claim in his state post-conviction proceeding and that the proceeding was dismissed with prejudice as a result.
2. Davis failed to state an access-to-courts claim based on limits on his access to electronic materials for his Arizona conditions-of-confinement litigation.
3. Restrictions allegedly preventing Davis from preparing or supporting a pardon application did not state a constitutional access-to-courts claim.
4. Davis failed to state a retaliation claim based solely on the allegation that his computer-lab access was reduced after he filed a lawsuit.
5. Davis was not entitled to a preliminary injunction because he failed to show a likelihood of success on the merits or future irreparable harm.

Questions Presented

1. Whether Davis plausibly stated access-to-courts claims under the First and Fourteenth Amendments based on Holmes’s and Sepeda’s alleged refusal to allow him to submit evidence in his state post-conviction proceeding.
2. Whether Davis plausibly stated access-to-courts claims based on restrictions affecting his Arizona conditions-of-confinement litigation.
3. Whether interference with a prisoner’s pardon application supports an access-to-courts claim.
4. Whether the alleged reduction in computer-lab access after Davis filed a lawsuit plausibly stated a First Amendment retaliation claim.
5. Whether alleged violations of Idaho law, the Idaho Constitution, or IDOC policies supported federal or state-law claims.
6. Whether Davis was entitled to a preliminary injunction.

Disposition

other