Francisco Rodriguez Santa v. M. McKinney, T. Quegan, and J. Marshall

Summary

The United States District Court for the Middle District of Florida dismisses a prisoner’s 42 U.S.C. § 1983 complaint alleging that prison officials violated the Fourteenth Amendment during disciplinary proceedings. The court concludes that the plaintiff’s 17-day confinement and temporarily revoked, but later restored, gain-time credits did not constitute an atypical and significant deprivation implicating a protected liberty interest. The action is dismissed without prejudice for failure to state a claim, and the court determines that amendment would be futile.

Holdings

1. A 17-day period of administrative confinement, together with a gain-time deprivation that was completely restored, did not constitute an atypical and significant deprivation sufficient to trigger procedural due-process protection under the Fourteenth Amendment.
2. Even assuming Plaintiff lacked advance notice of the disciplinary hearing and could not properly prepare a defense, the alleged procedural defects did not state a due-process claim because the disciplinary sanction did not deprive him of a constitutionally protected liberty interest.
3. The complaint failed to state a plausible Fourteenth Amendment due-process claim and was dismissed without prejudice under 28 U.S.C. § 1915(e)(2)(B)(ii).

Questions Presented

1. Whether Plaintiff plausibly alleged that the disciplinary proceedings deprived him of a constitutionally protected liberty interest under the Fourteenth Amendment.
2. Whether the alleged failure to provide advance notice and an adequate opportunity to prepare for the disciplinary hearing stated a due-process claim despite the later administrative reversal and restoration of gain-time credit.
3. Whether the complaint should be dismissed at initial screening for failure to state a claim and whether amendment would be futile.

Disposition

dismissed