Marquis Copez v. Gary Drozda and Leon Goodrich

Summary

The United States District Court for the District of Maryland dismissed Marquis Copez’s amended 42 U.S.C. § 1983 complaint against Gary Drozda and Leon Goodrich. The court held that allegations concerning a false or dismissed disciplinary report did not establish a federal constitutional violation and that Copez’s conclusory defamation allegations failed to state a claim under Maryland law. The court dismissed the amended complaint under 28 U.S.C. §§ 1915(e)(2)(B)(ii) and 1915A(b)(1), and denied pending motions as moot.

Holdings

1. The amended complaint did not state a federal constitutional claim because it alleged only that defendants wrote and approved a disciplinary report that was later dismissed, without alleging retaliation, arbitrary conduct, or a denial of procedural due process at the disciplinary hearing.
2. The amended complaint failed to state a Maryland defamation claim because it did not identify the allegedly false statements, allege how they were defamatory, or allege that the statements were communicated to third parties who caused Copez harm.
3. The amended complaint was dismissed for failure to state a claim under 28 U.S.C. §§ 1915(e)(2)(B)(ii) and 1915A(b)(1).

Questions Presented

1. Whether the allegations that defendants wrote and approved a false disciplinary report stated a federal constitutional claim under 42 U.S.C. § 1983.
2. Whether the amended complaint adequately pleaded a defamation claim under Maryland law.
3. Whether the court should dismiss the amended complaint during statutory screening.

Disposition

dismissed