Morgan v. Espinoza

Summary

The United States District Court for the Eastern District of California adopted in full the magistrate judge’s findings and recommendations concerning defendants’ motion to dismiss in a prisoner civil rights action under 42 U.S.C. § 1983. The court dismissed with prejudice the claims against defendant Hall, denied dismissal of the claim against defendant Espinoza concerning interference with witness testimony at a disciplinary hearing, and ordered Espinoza to answer.

Holdings

1. A prisoner has no federally recognized constitutional right to be free from false accusations of conduct that may result in deprivation of a protected liberty interest; therefore, plaintiff's claims against Hall were dismissed with prejudice.
2. Plaintiff sufficiently alleged that Espinoza interfered with his right to present witness testimony at his prison disciplinary hearing, and Espinoza was not entitled to dismissal of that claim on qualified-immunity grounds.

Questions Presented

1. Whether a prisoner may maintain a due process claim under § 1983 based solely on an allegedly false prison disciplinary charge.
2. Whether plaintiff sufficiently alleged that Espinoza interfered with his right to present witness testimony at a prison disciplinary hearing.
3. Whether Espinoza was entitled to dismissal on qualified-immunity grounds at the motion-to-dismiss stage.
4. Whether the magistrate judge's findings and recommendations should be adopted after de novo review.

Disposition

other