De'Shay Jarnaize Hackner v. Stephen C. Johns, Operations, IDOC Commissioner

Summary

The United States District Court for the Southern District of Indiana dismissed De'Shay Hackner's amended prisoner civil-rights complaint. The court held that the constitutional claims were barred by Indiana's two-year statute of limitations and, alternatively, failed to state viable equal-protection or PREA-related claims. The court dismissed the federal claims with prejudice, declined supplemental jurisdiction over the state-law claims, and dismissed those claims without prejudice.

Holdings

1. The federal constitutional claims were dismissed with prejudice because the allegations showed that the claims accrued more than two years before the action and the complaint provided no basis for tolling.
2. The amended complaint failed to state an equal-protection claim because it did not allege that the plaintiff was treated differently from a similarly situated person outside the protected class or that the defendants acted with discriminatory purpose.
3. The alleged failure to conduct a proper PREA investigation did not state a claim because the PREA creates no private cause of action and § 1983 does not provide a freestanding constitutional right to a PREA investigation.
4. The court declined to exercise supplemental jurisdiction over the state-law defamation claims and dismissed them without prejudice after dismissing all federal claims.
5. The plaintiff was not entitled to another opportunity to amend because any federal claim was clearly barred by the statute of limitations.

Questions Presented

1. Whether the plaintiff's federal constitutional claims were barred by Indiana's two-year statute of limitations.
2. Whether the amended complaint stated a Fourteenth Amendment equal-protection claim against the correctional and PREA officials.
3. Whether the alleged failure to investigate a PREA complaint stated a claim under the PREA or 42 U.S.C. § 1983.
4. Whether the court should exercise supplemental jurisdiction over the remaining state-law claims after dismissing all federal claims.
5. Whether the plaintiff should receive another opportunity to amend.

Disposition

dismissed