Alphonso Haynesworth v. Leonka Garvin, Dr. Dube, Lisa Young, Mr. Albrit, SVPTP, Henry McMaster, SC Department of Mental Health, and Alan Wilson; Alphonso Haynesworth v. Dr. Dube, Dr. Leonka Garvin, Lisa Young, Ron Lawrenz, Stephan Albrecht, Mr. Gaines, and Ms. Thompson

Summary

The United States District Court for the District of South Carolina adopted in part a Magistrate Judge’s Report and Recommendation in consolidated actions brought by Alphonso Haynesworth under 42 U.S.C. § 1983 and South Carolina law. The court denied Plaintiff’s motions for partial summary judgment, to strike, default, and default judgment; granted summary judgment to the Wellpath/Correct Care defendants; and dismissed Plaintiff’s federal claims with prejudice. The court dismissed the state-law gross-negligence claim without prejudice and dismissed the South Carolina Department of Mental Health and Alan Wilson without prejudice.

Holdings

1. The procedural due process claims arising from the disciplinary proceedings were dismissed with prejudice because the record showed Haynesworth was not punished and therefore no protected liberty interest was implicated; alternatively, the proceedings provided the minimum process required.
2. Haynesworth failed to establish unconstitutional retaliation. He did not show adverse action for the first incident, protected First Amendment activity for the second incident, or impermissible retaliation rather than a legitimate rule-violation charge for the third incident.
3. The claims construed as deliberate-indifference or substantive-due-process claims failed because the challenged actions were reasonably related to legitimate governmental objectives and were discretionary decisions by the treatment team; the supervisory-liability claims also failed because no underlying constitutional violation was shown.
4. The gross-negligence claim was dismissed without prejudice because Haynesworth failed to present evidence of a reckless breach of a duty of care or resulting damages.
5. The motions for entry of default and default judgment were denied, and any purported default was set aside for good cause.

Questions Presented

1. Whether Haynesworth was entitled to partial summary judgment or whether the Wellpath/Correct Care defendants were entitled to summary judgment on his procedural due process claims arising from the disciplinary proceedings.
2. Whether the alleged disciplinary actions and charges constituted unconstitutional retaliation for protected First Amendment activity.
3. Whether the alleged emotional distress, disciplinary actions, and treatment-team decisions stated a deliberate-indifference or substantive-due-process claim.
4. Whether Haynesworth produced evidence sufficient to support a state-law gross-negligence claim.
5. Whether the default-related motions should be denied and any purported default set aside for good cause.
6. Whether SCDMH and Alan Wilson should be dismissed without prejudice at Haynesworth's request.

Disposition

other