Juan Torres v. Sherman Day, et al.

Summary

The United States District Court for the Northern District of Indiana screens Juan Torres's amended prisoner complaint concerning a restitution sanction imposed after a prison disciplinary hearing. The court allows Torres to proceed against disciplinary hearing officer Sherman Day on a Fourteenth Amendment due process claim related to the June 2, 2022 restitution sanction, while dismissing claims against M. McGee and J. Morgan and denying preliminary injunctive relief. The order directs service on Day and dismisses all other claims.

Holdings

1. A prison disciplinary board may impose and collect restitution from an inmate’s prison account without a separate outside court order, provided the disciplinary proceeding includes constitutionally adequate procedural safeguards and the decision is supported by some evidence.
2. Torres may proceed against Sherman Day in his individual capacity on a Fourteenth Amendment claim concerning the imposition of the restitution sanction on June 2, 2022.
3. Torres failed to state a plausible constitutional claim against McGee or Morgan, and both were dismissed from the lawsuit.
4. The motion for a preliminary injunction was denied.

Questions Presented

1. Whether Torres plausibly stated a Fourteenth Amendment due-process claim based on the imposition of a restitution sanction without an outside court order.
2. Whether the complaint stated claims against the investigating officer and the official allegedly responsible for later deductions from Torres’s trust account.
3. Whether Torres was entitled to a preliminary injunction preventing further collection of restitution during the litigation.

Disposition

other