ALLEN v. KUHN

CourtDistrict Court, D. New Jersey
DecidedJune 12, 2025
Docket3:25-cv-03322
StatusUnknown

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

Bluebook
ALLEN v. KUHN, (D.N.J. 2025).

Opinion

NOT FOR PUBLICATION

UNITED STATES DISTRICT COURT DISTRICT OF NEW JERSEY

KAREEM ALLEN, Plaintiff, Civil Action No. 25-3322 (MAS) (JBD) OPINION VICTORIA KUHN, et al., Defendants.

SHIPP, District Judge This matter comes before the Court on Plaintiff Kareem Allen’s complaint (ECF No. 1) and application to proceed in forma pauperis. (ECF No. 1-1.) Having reviewed the application, Plaintiff shall be granted in forma pauperis status. Because Plaintiff shall be granted in forma pauperis status in this matter, the Court is required to screen Plaintiff's complaint pursuant to 28 U.S.C. § 1915(e)(2)(B) and dismiss any claim that is frivolous, malicious, fails to state a claim for relief, or seeks relief from an immune defendant. For the reasons set forth below, Plaintiff's complaint shall be dismissed without prejudice in its entirety for failure to state a claim upon which relief may be granted. I. BACKGROUND In his complaint, Plaintiff alleges that, in late January 2025, Defendant E. Marin Depascual filed a “false” disciplinary charge against him, resulting in Plaintiff being transferred to a restricted housing unit within Northern State Prison. (ECF No. 1 at 5-6.) Plaintiff remained there until March 3, 2025, when this disciplinary charge was “dismissed.” (/d.) Plaintiff contends that his

placement in this unit violated his rights because the restrictive housing unit limited his access to “medical attention, a shower, food, clean air, and [Plaintiffs] religious beliefs.” (Ud) Plaintiff does not provide details regarding how his access to these things was limited, nor does he detail what, if any, religious beliefs he observes. (/d.) Plaintiff does allege, however, that while in the restrictive housing unit, he was placed in a cell with a prisoner who had the flu, and that he contracted the illness. (/d.) Il. LEGAL STANDARD Pursuant to 28 U.S.C. § 1915(e)(2)(B), the Court must screen Plaintiff's complaint and sua sponte dismiss any claim that is frivolous, malicious, fails to state a claim upon which relief may be granted, or seeks monetary relief from a defendant who is immune from such relief. “The legal standard for dismissing a complaint for failure to state a claim pursuant to 28 U.S.C. § 1915(e)(2)(B)(ii) is the same as that for dismissing a complaint pursuant to Federal Rule of Civil Procedure 12(b)(6).” Schreane v. Seana, 506 F. App’x 120, 122 (3d Cir. 2012) (citing Allah vy. Seiverling, 229 F.3d 220, 223 (3d Cir. 2000)). In deciding a motion to dismiss pursuant to Federal Rule of Civil Procedure 12(b)(6), a district court is required to accept as true all factual allegations in the complaint and draw all reasonable inferences from those allegations in the light most favorable to the plaintiff, see Phillips v. County of Allegheny, 515 F.3d 224, 228 (3d Cir. 2008), but need not accept as true legal conclusions couched as factual allegations. Papasan v. Allain, 478 U.S. 265, 286 (1986). A complaint need not contain “detailed factual allegations” to survive a motion to dismiss, but must contain “more than an unadorned, the-defendant-unlawfully-harmed-me accusation.” Ashcroft v. Ighal, 556 U.S, 662, 678 (2009). A complaint “that offers ‘labels and conclusions’ or ‘a formulaic recitation of the elements of a cause of action will not do,’” and a complaint will not “suffice” if it provides only “‘naked assertion[s]’ devoid of ‘further factual enhancement.’” Jd. (quoting Bell

Atl. vy. Twombly, 550 US. 544, 555, 557 (2007)). “To survive a motion to dismiss, a complaint must contain sufficient factual matter, accepted as true, to ‘state a claim to relief that is plausible on its face.” /d. (quoting Twombly, 550 U.S. at 570). “A claim has facial plausibility when the plaintiff pleads factual content that allows the court to draw the reasonable inference that the defendant is liable for the misconduct alleged.” Jd. (quoting Twombly, 550 U.S. at 556). A complaint that provides facts “merely consistent with” the defendant’s liability “stops short of the line between possibility and plausibility” and will not survive review under Rule 12(b)(6). Jd. (quoting Twombly, 555 U.S. at 557). While pro se pleadings are to be liberally construed in conducting such an analysis, pro se litigants must still “allege sufficient facts in their complaints to support a claim.” Mala v. Crown Bay Marina, Inc., 704 F.3d 239, 245 (3d Cir. 2013). I. DISCUSSION In his complaint, Plaintiff alleges that he was subjected to placement in a restrictive housing unit based on false disciplinary charges, and that the three named Defendants — the officer who charged him, the Administrator of the prison in which Plaintiff is detained, and the commissioner of the NJ Department of Corrections — should be liable for alleged violations of his rights. “[T]he act of filing false disciplinary charges does not itself violate a prisoner’s constitutional rights,” and a prisoner’s rights will instead be violated only where he is denied Due Process in relation to those charges. Poole v. Mercer Cnty. Corr. Ctr., No. 11-3730, 2012 WL 694689, at *2 (D.N.J. Feb. 29, 2012); see also Mimms v. U.N.L.C.O.R., 386 F. App’x 32, 36 (3d Cir. 2010) (the “filing of false disciplinary charges does not constitute a claim under § 1983 so long as the inmate was granted a hearing and an opportunity to rebut the charges”); Smith v. Mensinger, 293 F.3d 641, 653-54 (3d Cir, 2002). Although Plaintiff alleges that the charges against him were false, he also states they were ultimately dismissed and does not allege that he was denied Due Process in relation to those

charges. Plaintiff's false disciplinary charge claims must therefore be dismissed without prejudice as to all three named Defendants. Plaintiff also seeks to raise an Eighth Amendment conditions of confinement claim related to his placement in a restrictive housing unit in connection to those charges. The placement of an inmate in restrictive housing — up to and including solitary confinement — for a brief period of just over a month pending the resolution of institutional charges, however, does not amount to a constitutional violation. See, e.g., Sandin v. Conner, 515 U.S. 472, 485-86 (1995). Because the Eighth Amendment does not mandate comfortable prisons, a conditions of confinement claim raised by a convicted prisoner such as Plaintiff may only proceed where the plaintiff alleges sufficient facts to indicate that he has been deprived of “the minimal civilized measure of life’s necessities” in light of the conditions of his confinement. Wilson v. Seiter, 501 U.S. 294, 298 (1991) (internal citations omitted, quoting Rhodes v. Chapman, 452 U.S 337 (1981)); see also Watson y. Sec’y Pa. Dep't of Corr., 567 F. App’x 75, 79 (3d Cir. 2014). An Eighth Amendment conditions of confinement claim thus has two elements.

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Related

Papasan v. Allain
478 U.S. 265 (Supreme Court, 1986)
Wilson v. Seiter
501 U.S. 294 (Supreme Court, 1991)
Sandin v. Conner
515 U.S. 472 (Supreme Court, 1995)
Reginald Mimms v. UNICOR
386 F. App'x 32 (Third Circuit, 2010)
Michael Malik Allah v. Thomas Seiverling
229 F.3d 220 (Third Circuit, 2000)
Clarence Schreane v. Seana
506 F. App'x 120 (Third Circuit, 2012)
Kelley Mala v. Crown Bay Marina
704 F.3d 239 (Third Circuit, 2013)
Farmer v. Brennan
511 U.S. 825 (Supreme Court, 1994)
Phillips v. County of Allegheny
515 F.3d 224 (Third Circuit, 2008)
Banks v. Secretary Pennsylvania Department of Corrections
601 F. App'x 101 (Third Circuit, 2015)
Smith v. Mensinger
293 F.3d 641 (Third Circuit, 2002)
Rode v. Dellarciprete
845 F.2d 1195 (Third Circuit, 1988)

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ALLEN v. KUHN, Counsel Stack Legal Research, https://law.counselstack.com/opinion/allen-v-kuhn-njd-2025.