Ashton Philip v. Tennessee Department of Corrections, et al.

CourtDistrict Court, E.D. Tennessee
DecidedMay 5, 2026
Docket3:26-cv-00146
StatusUnknown

This text of Ashton Philip v. Tennessee Department of Corrections, et al. (Ashton Philip v. Tennessee Department of Corrections, et al.) is published on Counsel Stack Legal Research, covering District Court, E.D. Tennessee primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Ashton Philip v. Tennessee Department of Corrections, et al., (E.D. Tenn. 2026).

Opinion

UNITED STATES DISTRICT COURT EASTERN DISTRICT OF TENNESSEE

ASHTON PHILIP, ) ) Plaintiff, ) ) v. ) No.: 3:26-CV-146-TAV-JEM ) TENNESSEE DEPARTMENT OF ) CORRECTIONS, et al., ) ) Defendants. )

MEMORANDUM OPINION AND ORDER Plaintiff Ashton Philip, a prisoner in the custody of the Tennessee Department of Correction (“TDOC”) currently incarcerated at the Bledsoe County Correctional Complex (“BCCX”), filed a (1) pro se civil rights complaint under 42 U.S.C. § 1983 [Doc. 2], (2) motion for leave to proceed in forma pauperis [Doc. 1], (3) motion for a court order requiring BCCX Warden Brett Cobble to provide Plaintiff with trust account information [Doc. 3], and (4) motion for a preliminary discovery order [Doc. 4]. For the reasons set forth below, the Court will GRANT Plaintiff’s motion to proceed in forma pauperis [Doc. 1]; permit his First Amendment mail-interference claim to PROCEED against Defendants TextBehind, Inc. (“TextBehind”), Brian Lovitt, and Aaron Hunley; DISMISS all remaining claims and Defendants; and DENY AS MOOT Plaintiff’s motion for trust account information [Doc. 3] and motion for a preliminary discovery order [Doc. 4]. I. FILING FEE Under the Prison Litigation Reform Act (“PLRA”), a prisoner bringing a civil action may apply for permission to file suit without prepaying the filing fee. See 28 U.S.C. § 1915(a). A review of Plaintiff’s motion to proceed in forma pauperis [Doc. 1] and accompanying documents [Doc. 7] demonstrates that he lacks sufficient financial resources to pay the filing fee in a lump sum. Accordingly, pursuant to 28 U.S.C. § 1915, this motion [Doc. 1] will be GRANTED. And because Plaintiff has now submitted the necessary documents to proceed as a pauper, his motion for a court order to obtain the information [Doc. 3] will be DENIED

as moot. Plaintiff will be ASSESSED the civil filing fee of $350.00. The custodian of Plaintiff’s inmate trust account will be DIRECTED to submit to the Clerk, U.S. District Court, 800 Market Street, Suite 130, Knoxville, Tennessee, 37902 twenty percent (20%) of Plaintiff’s preceding monthly income (or income credited to Plaintiff’s trust account for the preceding month), but only when such monthly income exceeds ten dollars ($10.00), until the full filing fee of three hundred fifty dollars ($350.00) as authorized under 28 U.S.C. § 1914(a) has been paid to the Clerk. 28 U.S.C. § 1915(b)(2).

The Clerk will be DIRECTED to send a copy of this Order to the Court’s financial deputy and the custodian of inmate trust accounts at Plaintiff’s current facility to ensure compliance with payment of the filing fee. II. COMPLAINT SCREENING A. Screening Standard Under the PLRA, district courts must screen prisoner complaints and sua sponte dismiss any claims that are “frivolous, malicious, or fail[] to state a claim upon which relief may be granted,” or “seek[] monetary relief from a defendant who is immune from such relief.” 28 U.S.C. § 1915A(b); see also 28 U.S.C. § 1915(e)(2)(B); Benson v. O’Brian, 179 F.3d 1014

(6th Cir. 1999). The dismissal standard articulated by the Supreme Court in Ashcroft v. Iqbal, 556 U.S. 662 (2009) and Bell Atlantic Corporation v. Twombly, 550 U.S. 544 (2007) “governs dismissals for failure to state a claim under [28 U.S.C. §§ 1915(e)(2)(B) and 1915A] because the relevant statutory language tracks the language in Rule 12(b)(6)” of the Federal Rules of Civil Procedure. Hill v. Lappin, 630 F.3d 468, 470–71 (6th Cir. 2010) (citations omitted). Thus, to survive an initial review under the PLRA, a complaint “must contain sufficient factual

matter, accepted as true, to ‘state a claim to relief that is plausible on its face.’” Iqbal, 556 U.S. at 678 (quoting Twombly, 550 U.S. at 570). Courts should liberally construe pro se pleadings filed in civil rights cases and hold them to a less stringent standard than lawyer-drafted pleadings. Haines v. Kerner, 404 U.S. 519, 520 (1972). Even so, allegations that give rise to a mere possibility that a plaintiff might later establish undisclosed facts supporting recovery are not well-pled and do not state a plausible claim. Twombly, 550 U.S. at 555, 570. Further, formulaic and conclusory recitations of the elements of a claim which are not supported by specific facts are insufficient to state a

plausible claim for relief. Iqbal, 556 U.S. at 681. B. Plaintiff’s Allegations TextBehind has a contract with TDOC to digitize incoming, non-legal inmate mail [Doc. 2, p. 12]. TextBehind scans inmate mail, and it is then made available to inmates for viewing via an electronic tablet [Id. at 13]. Claim One. On December 2, 2025, Plaintiff received a notification from TextBehind that his mail—“a religious magazine from the United Church of God”—was being rejected for scanning because it was bound with staples [Id. at 14]. But staples are not prohibited by TDOC’s mail policy, and TextBehind’s refusal to scan the magazine violated Plaintiff’s First,

Fourth, and Fourteenth Amendment rights [Id.]. Plaintiff filed a grievance about the matter on December 5, 2025, maintaining that the magazine should have been provided to him at BCCX in accordance with TDOC Policy 507.02, instead of being forwarded to TextBehind for scanning [Id. at 15]. Ray Worthington refused to process Plaintiff’s grievance, however, and returned it to Plaintiff with a notation that he was complaining about matters inappropriate to the grievance process and involving the decisions of an outside agency [Id.]. Therefore,

Worthington’s actions violated Plaintiff’s First and Fourteenth Amendment rights [Id. at 16]. But Plaintiff’s grievance conformed to the requirements of TDOC’s grievance policy and sought redress for the actions of TDOC employees—Brian Lovitt and Aaron Hunley [Id. at 15–16]. Pursuant to TDOC policy 507.02, Plaintiff should have received his religious magazine at BCCX [Id. at 18]. Instead, mailroom employees Lovitt and Hunley seized his mail and forwarded it to TextBehind, where it was destroyed [Id.]. This violated Plaintiff’s First, Fourth, and Fourteenth Amendment rights [Id. at 18–19]. Plaintiff appealed Worthington’s response to BCCX Warden Brett Cobble [Id. at 16].

Warden Cobble had the responsibility to “correct the improper forwarding of Plaintiff[’]s religious magazine to TextBehind, Inc., as the mail addressed to [P]laintiff conformed to” TDOC’s mail policy “and should have been received by Plaintiff at BCCX” [Id. at 17]. But Warden Cobble failed to investigate Plaintiff’s claims and “rubber stamped” Worthington’s actions, which violated Plaintiff’s First and Fourteenth Amendment rights [Id. at 16–17].

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