Sammie L. Smith v. Mary J. Leiser and Adam Baranowski

Summary

The United States District Court for the Western District of Wisconsin screened Sammie L. Smith’s pro se 42 U.S.C. § 1983 complaint concerning the handling of inmate grievances by correctional complaint examiners. The court held that the allegations did not state claims for denial of grievance-related rights, retaliation, due process, or failure to investigate. The complaint was dismissed without prejudice, and Smith was granted until May 12, 2026, to file an amended complaint.

Holdings

1. The rejection or denial of inmate grievances, without more, does not state a First Amendment claim because the First Amendment right to petition the government does not guarantee a particular result.
2. Smith failed to state a First Amendment retaliation claim because he did not allege that he engaged in protected activity concerning Leiser before Leiser allegedly made the retaliatory statement.
3. Smith failed to state a due process claim because he had no protected interest in legal-loan resources.
4. An inmate's allegation that a prison official failed to investigate another official's conduct does not, by itself, state a constitutional claim.
5. The alleged mishandling, failure to process, or discarding of inmate grievances did not state a constitutional claim where the defendants did not cause or participate in the underlying misconduct and the alleged conduct was not sufficiently deterrent to support retaliation.

Questions Presented

1. Whether rejecting or denying Smith's inmate grievances stated a First Amendment claim.
2. Whether Leiser's alleged statement that Smith was ineligible for a legal loan stated a First Amendment retaliation claim.
3. Whether the alleged denial of legal-loan resources stated a due process claim.
4. Whether Baranowski's failure to investigate Leiser stated a constitutional claim.
5. Whether the alleged mishandling or nonprocessing of Smith's grievances stated a First Amendment retaliation or other constitutional claim.

Disposition

dismissed