Shawn Randall v. C/O Robert Gearhart, Lt. Dallas, Sgt. Woodley, Jacob Guetersloh, Kevin Reichert, Sandy Walker, Anthony Wills, Anthony B. Jones, Angela Locke, C/O Chandler, C/O Heins, C/O Baker, C/O Choate, C/O Farrar, C/O Bent, Ms. Salger, Ms. Phillips, C/O Falaster, C/O McClanahan

Summary

The court conducts preliminary screening of Shawn Randall’s amended 42 U.S.C. § 1983 complaint concerning prison disciplinary proceedings, segregation conditions, and mental-health care. The court dismisses the due process and retaliation-related claims without prejudice, allows an Eighth Amendment yard-access claim to proceed against Anthony Wills and McClanahan, and allows a deliberate-indifference-to-mental-health-needs claim to proceed against Salger and Phillips. All other claims and defendants are dismissed without prejudice.

Holdings

1. Randall failed to state a due process claim merely because he was charged again for the same infraction after being found not guilty on the first ticket, because double-jeopardy principles do not apply in the prison-disciplinary context.
2. An inmate is entitled to due process only when the challenged deprivation imposes an atypical and significant hardship, and where segregation is imposed without loss of good-time credit, informal due process requires notice of the reasons for segregation and an opportunity to present the inmate’s views in writing or at a hearing.
3. Randall plausibly stated an Eighth Amendment deliberate-indifference claim against Anthony Wills and McClanahan based on alleged denial of yard access while in segregation, but failed to state a claim against the correctional officers whose alleged involvement was described only in general and conclusory terms.
4. Randall stated an Eighth Amendment claim against Salger and Phillips by alleging that he had mental-health needs and that they ignored his repeated requests for mental-health care.
5. Randall failed to state a retaliation claim because he did not identify protected First Amendment activity that motivated Gearhart’s issuance of the second disciplinary ticket.
6. Randall failed to state a First Amendment claim based on placement on mail-scan status because prison mail restrictions may be imposed when reasonably related to legitimate penological interests, and he did not allege that he was prohibited from accessing his mail.

Questions Presented

1. Whether Randall stated a Fourteenth Amendment due process claim based on being charged a second time after being found not guilty on the first disciplinary ticket.
2. Whether Randall stated a due process claim based on allegedly inadequate notice of the charges and disciplinary evidence.
3. Whether Randall stated an Eighth Amendment conditions-of-confinement claim based on denial of yard or recreation while in segregation.
4. Whether Randall stated an Eighth Amendment deliberate-indifference claim based on alleged denial of mental-health care.
5. Whether Randall stated a First Amendment retaliation claim based on issuance of the second disciplinary ticket.
6. Whether Randall stated a First Amendment claim based on placement on mail-scan status.

Disposition

other