Marquis Taylor v. Governor Glenn Youngkin

Summary

The United States District Court for the Eastern District of Virginia dismisses Marquis Taylor’s pro se 42 U.S.C. § 1983 action against Governor Glenn Youngkin. Taylor alleged that the Governor’s failure to sign legislation allowing resentencing for certain prior marijuana convictions violated due process. The court held that Taylor had no protected liberty interest in the enactment of the proposed legislation and dismissed the claims as failing to state a claim and as legally frivolous.

Holdings

1. Taylor had no protected liberty interest in having the proposed bill passed or signed by the Governor.
2. The complaint failed to state a procedural due-process claim and was legally frivolous.

Questions Presented

1. Whether Taylor had a protected liberty or property interest in the Governor's signing of proposed legislation that would have allowed resentencing for his prior marijuana conviction.
2. Whether the complaint stated a procedural due-process claim under the Fourteenth Amendment.
3. Whether the action was frivolous or failed to state a claim under the PLRA screening provisions.

Disposition

dismissed