Cordell Sanders v. Deanna Brookhart and J. Brown

Summary

The United States District Court for the Southern District of Illinois screened Cordell Sanders’s pro se 42 U.S.C. § 1983 complaint alleging that prison officials denied him access to programs eligible for earned program sentence credit. The court held that the allegations plausibly stated a Fourteenth Amendment Equal Protection claim because similarly situated general-population inmates in different housing units allegedly received unequal access without an apparent rational basis. The claim proceeded against Warden Deanna Brookhart and Assistant Warden J. Brown.

Holdings

1. The complaint plausibly alleged an equal protection claim because it asserted that general-population inmates in different housing units received unequal access to sentence-credit programs and that the distinction had no rational relationship to a legitimate penological interest.
2. Count 1 survived screening under 28 U.S.C. § 1915A and could proceed against Deanna Brookhart and J. Brown.

Questions Presented

1. Whether the complaint plausibly alleged that defendants violated the Fourteenth Amendment Equal Protection Clause by denying Sanders access to earned-program-sentence-credit programs available to similarly situated general-population inmates housed in other units.
2. Whether the complaint survived screening under 28 U.S.C. § 1915A.

Disposition

other