Amilcar Joshua Quintana v. Allen, et al.

Summary

The United States District Court for the Western District of Virginia reviews Amilcar Joshua Quintana’s amended pro se complaint under 28 U.S.C. § 1915A. Quintana alleged that correctional officials lost or misplaced legal documents, forged or interfered with a grievance withdrawal, and retaliated against him, asserting constitutional and federal statutory claims. The court concludes that the federal claims fail to state a claim and declines supplemental jurisdiction over any remaining state-law claims.

Holdings

1. The alleged interference with or mishandling of a particular prison grievance did not, without more, establish a First Amendment violation because inmates have no constitutional entitlement to a specific grievance procedure.
2. Quintana failed to state an access-to-the-courts claim because he did not allege an actual injury involving the loss or frustration of a nonfrivolous legal claim.
3. Quintana failed to state a First Amendment retaliation claim because he did not plausibly allege that defendants' conduct would deter a person of ordinary firmness from exercising First Amendment rights or caused more than a de minimis inconvenience.
4. Quintana could not state a Fifth Amendment due process claim against state correctional officials because the Fifth Amendment applies to federal, not state, actors.
5. Quintana failed to state an Eighth Amendment claim because he did not allege a serious deprivation or that any defendant consciously disregarded an excessive risk to his health or safety.
6. The Ninth Amendment claim failed because the Ninth Amendment creates no independent constitutional rights, and the Thirteenth Amendment claim failed because Quintana alleged no involuntary servitude or forced labor.
7. Quintana failed to state a procedural due process claim based on lost property or grievance handling because Virginia provides an adequate post-deprivation remedy and inmates have no federally protected interest in a particular grievance process or outcome.
8. Quintana failed to state an equal protection claim because he alleged neither differential treatment of similarly situated persons nor intentional discrimination, and he failed to state an Article IV claim because he alleged no discrimination based on out-of-state residency.
9. Quintana could not pursue civil claims under 18 U.S.C. §§ 2 or 922(a)(6) because those criminal provisions do not create an express or implied private right of action.
10. Quintana failed to state claims under §§ 1981 and 1985(3) because he alleged no race-based or other class-based discriminatory animus, and he could not maintain a private action under § 1997d because its anti-retaliation provision does not create a private right of action.
11. The court declined to exercise supplemental jurisdiction over Quintana's state-law claims after dismissing all claims over which it had original jurisdiction.

Questions Presented

1. Whether Quintana stated a First Amendment claim based on alleged interference with the prison grievance process, denial of access to the courts, or retaliation.
2. Whether Quintana stated a claim under the Fifth, Eighth, Ninth, or Thirteenth Amendments.
3. Whether the alleged loss or misplacement of legal documents or interference with grievances stated a procedural due process claim under the Fourteenth Amendment.
4. Whether Quintana stated an equal protection claim under the Fourteenth Amendment or a privileges-and-immunities claim under Article IV.
5. Whether Quintana stated claims under 18 U.S.C. §§ 2 and 922(a)(6), 42 U.S.C. §§ 1981, 1985(3), or 1997d.
6. Whether the court should exercise supplemental jurisdiction over the remaining state-law claims after dismissing all federal claims.

Disposition

dismissed