Marcus Antonio Satterfield v. Avery Mitchell Correctional Institution, et al.

Summary

This memorandum of decision and order addresses the initial review of Marcus Antonio Satterfield’s 42 U.S.C. § 1983 prisoner complaint under 28 U.S.C. §§ 1915(e)(2) and 1915A. The court allowed an individual-capacity Eighth Amendment excessive-force claim against Defendant Matthan Hicks and an individual-capacity First Amendment retaliation claim against Defendants Landon Brown and Loren Aldrige to proceed, while dismissing the remaining claims and defendants.

Holdings

1. The complaint stated a nonfrivolous individual-capacity Eighth Amendment excessive-force claim against Hicks, which could proceed beyond initial review.
2. The complaint failed to state an Eighth Amendment claim against Strafford and Ellis based on verbal harassment, a threat, or their alleged presence during Hicks's use of force.
3. NCDAC and AMCI were not persons subject to suit under 42 U.S.C. § 1983, so the claims against them were dismissed with prejudice.
4. The official-capacity claims against the state officials did not survive initial review and were dismissed.
5. The complaint stated a nonfrivolous individual-capacity First Amendment retaliation claim against Brown and Aldrige, which could proceed beyond initial review.
6. The complaint failed to state a § 1983 claim based on denial of access to or interference with prison grievance procedures.
7. The claim based on allegedly false disciplinary charges appeared barred by Heck because Satterfield did not allege that the disciplinary convictions had been reversed or otherwise invalidated.
8. The complaint failed to state a due process claim because it contained vague and conclusory allegations and did not identify the defendant responsible or allege deprivation of the procedural protections required by Wolff.

Questions Presented

1. Whether the complaint stated a nonfrivolous individual-capacity Eighth Amendment excessive-force claim against Hicks.
2. Whether the complaint stated Eighth Amendment claims against Strafford and Ellis based on verbal harassment, a threat, or failure to protect Satterfield from Hicks's alleged use of force.
3. Whether NCDAC and AMCI were suable persons under 42 U.S.C. § 1983.
4. Whether official-capacity claims for damages were barred because state officials are not persons under § 1983 and are protected by Eleventh Amendment immunity.
5. Whether the complaint stated a First Amendment retaliation claim against Brown and Aldrige.
6. Whether the alleged denial or interference with grievance procedures stated a constitutional claim.
7. Whether claims based on allegedly false disciplinary charges were barred by Heck v. Humphrey and Edwards v. Balisok.
8. Whether the allegations stated a procedural or substantive due process claim arising from prison disciplinary proceedings.

Disposition

other