Khalif Abdul Mateen v. L. Smith, et al.

Summary

The court screened Khalif Abdul Mateen’s prisoner civil-rights complaint under 28 U.S.C. § 1915A. It concluded that the allegations concerning segregation conditions, disciplinary proceedings, Ramadan meals, fire-safety systems, and the grievance process did not state a constitutional claim, but granted Mateen leave to amend. The court ordered him to file an amended complaint by March 2, 2026, warning that failure to do so would result in dismissal.

Holdings

1. Mateen's initial twelve-day placement in a special-management cell was too short to implicate due-process protections, and the alleged conditions did not independently establish a constitutional violation.
2. The alleged conditions did not plausibly state an Eighth Amendment claim because they did not deny Mateen the minimal civilized measure of life's necessities or exceed contemporary bounds of decency.
3. Mateen did not state a procedural due-process claim because he did not identify a deficiency in the notice, hearing, opportunity to present evidence, written decision, or evidentiary support for the disciplinary finding.
4. The alleged failure to provide a photograph or other documentation of the officer's injury did not state a constitutional claim because the asserted requirement arose from IDOC policy rather than the Due Process Clause.
5. Those allegations did not state a constitutional claim; in particular, Mateen had no constitutional right to a grievance procedure, and he did not allege that the Ramadan food violated his religious beliefs or that a particular defendant was responsible for the alleged Establishment Clause violation.

Questions Presented

1. Whether Mateen's twelve-day placement in a special-management cell under the alleged conditions implicated a protected liberty interest under the Fourteenth Amendment.
2. Whether the conditions of Mateen's twelve-day special-management placement or his later confinement in D cell house stated an Eighth Amendment claim.
3. Whether Mateen alleged a procedural due-process violation in connection with his prison disciplinary proceedings and rehearing.
4. Whether the absence of injury documentation required by IDOC policy invalidated the disciplinary finding under the Constitution.
5. Whether the allegations concerning Ramadan meals, the absence of an Eid al-Fitr meal, fire-safety conditions, and the grievance process stated constitutional claims.

Disposition

other