Allen v. Brown

CourtDistrict Court, E.D. Arkansas
DecidedMay 9, 2023
Docket4:23-cv-00198
StatusUnknown

This text of Allen v. Brown (Allen v. Brown) is published on Counsel Stack Legal Research, covering District Court, E.D. Arkansas primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Allen v. Brown, (E.D. Ark. 2023).

Opinion

IN THE UNITED STATES DISTRICT COURT EASTERN DISTRICT OF ARKANSAS CENTRAL DIVISION

ZACHERY TREY ALLEN PLAINTIFF ADC #158242

v. No: 4:23-cv-00198-KGB-PSH

STEVEN D. BROWN, et al. 1 DEFENDANTS

PROPOSED FINDINGS AND RECOMMENDATION

INSTRUCTIONS

The following Proposed Recommendation has been sent to United States District Judge Kristine G. Baker. You may file written objections to all or part of this Recommendation. If you do so, those objections must: (1) specifically explain the factual and/or legal basis for your objection, and (2) be received by the Clerk of this Court within fourteen (14) days of this Recommendation. By not objecting, you may waive the right to appeal questions of fact. DISPOSITION Plaintiff Zachery Trey Allen filed a pro se complaint pursuant to 42 U.S.C. § 1983 (Doc. No. 2) while incarcerated at the Arkansas Division of Correction’s Tucker Unit. Allen was subsequently granted leave to proceed in forma pauperis

1 The Clerk of Court is directed to remove Warden Todd Ball as a defendant in this case because he is not listed as a defendant or described in Allen’s amended complaint (Doc. No. 7). and invited to file an amended complaint to clarify and narrow his claims. Doc. Nos. 4 & 6. He was cautioned that an amended complaint would render his original

complaint without legal effect and that only claims properly set out in the amended complaint would be allowed to proceed. Doc. No. 6 at 4. Allen filed an amended complaint on May 2, 2023 (Doc. No. 7). The Court has liberally construed2 Allen’s

amended complaint for screening purposes and finds that his claims should be dismissed for failure to state a claim upon which relief may be granted. I. Screening Standard Federal law requires courts to screen prisoner complaints. 28 U.S.C. § 1915A,

1915(e)(2). Claims that are legally frivolous or malicious; that fail to state a claim for relief; or that seek money from a defendant who is immune from paying damages should be dismissed before the defendants are served. 28 U.S.C. § 1915A,

1915(e)(2). Although a complaint requires only a short and plain statement of the claim showing that the pleader is entitled to relief, the factual allegations set forth therein must be sufficient to raise the right to relief above the speculative level. See Fed. R. Civ. P. 8(a)(2); Bell Atlantic Corporation v. Twombly, 550 U.S. 544, 555

(2007) (“a plaintiff’s obligation to provide the ‘grounds’ of his ‘entitle[ment]to

2 See Stone v. Harry, 364 F.3d 912, 915 (8th Cir. 2004) (“When we say that a pro se complaint should be given liberal construction, we mean that if the essence of an allegation is discernible, even though it is not pleaded with legal nicety, then the district court should construe the complaint in a way that permits the layperson’s claim to be considered within the proper legal framework.”). relief’ requires more than labels and conclusions, and a formulaic recitation of the elements of a cause of action will not do. . . .”). While construed liberally, a pro se

complaint must contain enough facts to state a claim to relief that is plausible on its face, not merely conceivable. II. Analysis

To state a claim under 42 U.S.C. § 1983, a plaintiff must allege that the conduct of a defendant acting under color of state law deprived him of a right, privilege, or immunity secured by the United States Constitution or by federal law. 42 U.S.C. § 1983.

Allen complains that defendants Sergeant David Hutchinson and Corporal Jerome Eason placed him in an isolation cell on January 1, 2023, with no clothing or a blanket on the orders of Lieutenant Steven Brown. Doc. No. 7 at 4. He claims

that Sergeant Roberson denied him a blanket or boxers on January 2, 2023, and that Major Johnson released him on January 4, 2023, but denied witnessing him naked. Id. Allen claims that temperatures outside were below 40 and the fans were turned on for two days. Id. Allen fails to state a claim upon which relief may be granted

for the reasons described below. The treatment a prisoner receives in prison and the conditions of his confinement are subject to scrutiny under the Eighth Amendment. Farmer v.

Brennan, 511 U.S. 825, 832 (1970). To prevail on a conditions of confinement claim, a prisoner must show (1) the alleged deprivation was, “objectively, sufficiently serious,” and resulted “in the denial of the minimal civilized measure of

life’s necessities,” and (2) prison officials were deliberately indifferent to “an excessive risk to inmate health or safety.” Farmer, 511 at 834. “The Constitution ‘does not mandate comfortable prisons,’ but neither does it permit inhumane ones, .

. . ” Farmer v. Brennan, 511 U.S. at 832 (quoting Rhodes v. Chapman, 452 U.S. 337, 349 (1981)); see also O’Leary v. Iowa State Men’s Reformatory, 79 F.3d 82, 83–84 (8th Cir. 1996) (no constitutional violation for limited denial of underwear, blankets, mattress, exercise, and visits); Williams v. Delo, 49 F.3d 442, 446 (8th

Cir.1995) (no constitutional violation for inmate confined to a “strip cell” for four days without clothes, water, bedding, a mattress, soap, or other hygiene items); Seltzer-Bey v. Delo, 66 F.3d 961, 963-964 (8th Cir. 1995) (finding no Eighth

Amendment violation when inmate was placed in “strip cell for two days without clothing, bedding, or running water, with a concrete floor, a concrete slab for a bed, and cold air blowing on him”). The Eighth Amendment guarantees prisoners the right to adequate shelter and

protection from extreme cold, and courts examine allegations of the severity of the cold and the length of time a prisoner is exposed to it in determining whether there has been a constitutional violation. Dixon v. Godinez, 114 F.3d 640, 642 (7th Cir.

1997). See e.g., Corselli v. Coughlin, 842 F.2d 23, 27 (2d Cir. 1988) (plaintiff alleged he was exposed to cold temperatures for approximately three months and it was so cold that ice was forming in his toilet); Dixon v. Godinez, 114 F.3d at 644

(plaintiff testified “that ice persistently formed on the walls of the cells suggest[ed] that temperatures in the cell block were literally freezing, during the day as well as at night, and that this condition continued unchanged for several winters”); Bennett

v. Chitwood, 519 Fed. Appx. 569, 574 (11th Cir.

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Related

Carey v. Piphus
435 U.S. 247 (Supreme Court, 1978)
Rhodes v. Chapman
452 U.S. 337 (Supreme Court, 1981)
Bell Atlantic Corp. v. Twombly
550 U.S. 544 (Supreme Court, 2007)
David S. Bennett v. Cpt. Wesley Lynch
519 F. App'x 569 (Eleventh Circuit, 2013)
Farmer v. Brennan
511 U.S. 825 (Supreme Court, 1994)
Irving v. Dormire
519 F.3d 441 (Eighth Circuit, 2008)

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Allen v. Brown, Counsel Stack Legal Research, https://law.counselstack.com/opinion/allen-v-brown-ared-2023.