Benton v. Joyner

CourtDistrict Court, E.D. Kentucky
DecidedMay 5, 2022
Docket7:20-cv-00131
StatusUnknown

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

Bluebook
Benton v. Joyner, (E.D. Ky. 2022).

Opinion

UNITED STATES DISTRICT COURT EASTERN DISTRICT OF KENTUCKY SOUTHERN DIVISION PIKEVILLE

JEFFREY BENTON, ) ) Plaintiff, ) Civil Action No. 7:20-cv-131-GFVT ) v. ) ) HECTOR JOYNER, et. al., ) MEMORANDUM OPINION ) & Defendants. ) ORDER

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Inmate Jeffrey Benton is an inmate confined at the federal penitentiary in Inez, Kentucky. Benton has filed a pro se complaint asserting civil rights claims against federal officials pursuant to the doctrine announced in Bivens v. Six Unknown Federal Narcotics Agents, 403 U.S. 388 (1971). [R. 1.] This matter is before the Court to conduct the preliminary screening required by 28 U.S.C. §§ 1915(e)(2), 1915A. Davis v. Prison Health Servs., 679 F.3d 433, 437-38 (6th Cir. 2012). When testing the sufficiency of the plaintiff’s complaint, the Court affords it a forgiving construction, accepting as true all non-conclusory factual allegations and liberally construing its legal claims in the plaintiff’s favor. Davis v. Prison Health Servs., 679 F.3d 433, 437-38 (6th Cir. 2012). A district court must dismiss any claim that is frivolous or 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. Hill v. Lappin, 630 F. 3d 468, 470-71 (6th Cir. 2010). In his complaint, Benton states that the prison has been under a “modified lockdown status” on numerous occasions for more than a year. During such periods, inmates have only limited access to recreation, telephones, showers, educational programming, and the law library. As a result of these lockdowns, Benton states that he has “been losing family support and going thru emotional situations.” Benton names as defendants Warden Joyner, Assistant Warden E. A. Earwin, Captain D. Altizer, and Captain M. Duff. He seeks monetary damages and transfer to a

different prison. [R. 1 at 1-3, 8.] The Court has thoroughly reviewed the complaint and the materials Benton has filed in support of it, but concludes that it must be dismissed for failure to state upon which relief may be granted. First, while Benton has named Assistant Warden Earwin and Captains Altizer and Duff as defendants, he makes no allegations against them. The absence of necessary and sufficient allegations against each defendant fails to satisfy federal notice pleading requirements. The claims against these defendants must be dismissed. See Sampson v. Garrett, 917 F. 3d 880, 882 (6th Cir. 2019) (“[e]ven a pro se prisoner must link his allegations to material facts … and indicate what each defendant did to violate his rights …”). Benton implies, without expressly alleging, that Warden Joyner implemented the prison

policies about which he complains. The Court assumes without deciding that this is sufficient as a matter of pleading. It takes the same approach to the question of whether the right of action implied by Bivens reaches the conduct at issue here. See Callahan v. Fed. Bureau of Prisons, 965 F.3d 520, 523 (6th Cir. 2020) (“What started out as a presumption in favor of implied rights of action [under Bivens] has become a firm presumption against them.”). Regardless, Benton’s allegations regarding the prison conditions to which he was subjected do not state a claim for violation of his constitutional rights. The Eighth Amendment prohibits “cruel and unusual punishments,” which applies to the conditions of a prisoner’s confinement. Rhodes v. Chapman, 452 U.S. 337, 345-46 (1981). Because “the Constitution does not mandate comfortable prisons,” prison conditions that are “restrictive and even harsh” do not violate the Eighth Amendment so long as they constitute no more than “part of the penalty that criminal offenders pay for their offenses against society.” Id. at 347. To state a viable Eighth Amendment claim, a plaintiff must plausibly assert that prison

officials acted with deliberate indifference to a substantial risk of serious harm. Curry v. Scott, 249 F. 3d 493, 506 (6th Cir. 2001). To do so, the inmate must allege that the prison official had actual knowledge that a condition at the prison exposed the inmate to an excessive risk to his health or safety, but recklessly disregarded the risk. Farmer v. Brennan, 511 U.S. 825, 836 (1994); Mingus v. Butler, 591 F.3d 474, 480 (6th Cir. 2010). He must also allege that as a result of the official’s action or inaction he suffered a sufficiently serious deprivation. Mattox v. Edelman, 851 F.3d 583, 597 (6th Cir. 2017). Here, while Benton implies that the warden was responsible for the modified lockdowns to which he objects, he makes no allegation that Joyner was subjectively aware that they were likely to result in serious harm to Benton or other inmates, let alone intentionally disregarded that

risk. To the contrary, the BOP memoranda he attached to the complaint, [R. 1-4; R. 1-6], suggest that the lockdowns were ordered in an effort to quell a prison riot and to reduce the risk of transmission of the coronavirus. Without a necessary allegation sufficient to establish the required subjective component by any of the defendants, Benton fails to plead a plausible claim under the Eighth Amendment. Further, Benton’s individual grievances do not indicate violation of the Eighth Amendment. With respect to recreation, the complete denial of any recreational exercise may violate the Constitution. Walker v. Mintzes, 771 F.2d 920, 927 (6th Cir. 1985). But Benton complains only that the hour of recreation to which he had become accustomed in 2019 was not always provided in 2020 as the BOP adapted to the threats posed by COVID-19 during the tumultuous first year of the pandemic. The Sixth Circuit has refused to define any constitutionally-mandated minimum of recreation, and noted that “differences in circumstances” may warrant variations in the amount of yard or recreational time permitted. Id. at 927-28. The

inconveniences described by Benton’s allegations fail to indicate a sufficiently-serious deprivation to implicate the Eighth Amendment. Cf. Brown v. Kelly, No. 4:12 CV 1356, 2012 WL 5877424, at *3 (N.D. Ohio Nov. 20, 2012) (inmate’s allegation that he was “denied recreation or has his recreation time cut short when violence erupts” not sufficient to state Eighth Amendment claim); Hancock v. Rowland, No. 1:15-CV-00055, 2015 WL 4459171, at *4 (M.D. Tenn. July 20, 2015) (“The occasional loss of recreation time to accommodate visitation” does not amount to an “atypical and significant hardship on the inmate in relation to the ordinary incidents of prison life.”) (quoting Sandin v. Conner, 515 U.S. 472, 484 (1995)). The other matters described by Benton, such as infrequent showers and limited access to telephones and educational programming, do not amount to a violation of his constitutional

rights. Cf. Ziegler v. Michigan, 59 F. App’x 622, 624 (6th Cir. 2003); Govereh v. Pugh, No. 4:12 CV 697, 2012 WL 3683541, at *4 (N.D. Ohio Aug.

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Related

Rhodes v. Chapman
452 U.S. 337 (Supreme Court, 1981)
Sandin v. Conner
515 U.S. 472 (Supreme Court, 1995)
Lewis v. Casey
518 U.S. 343 (Supreme Court, 1996)
Hill v. Lappin
630 F.3d 468 (Sixth Circuit, 2010)
Granader v. Public Bank
417 F.2d 75 (Sixth Circuit, 1969)
Gary William Holt v. Jerry Pitts, Sheriff
702 F.2d 639 (Sixth Circuit, 1983)
Torrance Pilgrim v. John Littlefield
92 F.3d 413 (Sixth Circuit, 1996)
Greg Curry v. David Scott
249 F.3d 493 (Sixth Circuit, 2001)
Davis v. Prison Health Services
679 F.3d 433 (Sixth Circuit, 2012)
Farmer v. Brennan
511 U.S. 825 (Supreme Court, 1994)
Demis v. Sniezek
558 F.3d 508 (Sixth Circuit, 2009)
Mingus v. Butler
591 F.3d 474 (Sixth Circuit, 2010)
Todd Mattox v. Adam Edelman
851 F.3d 583 (Sixth Circuit, 2017)
Timothy Sampson v. Cathy Garrett
917 F.3d 880 (Sixth Circuit, 2019)
Scott Callahan v. Fed. Bureau of Prisons
965 F.3d 520 (Sixth Circuit, 2020)
Ziegler v. Michigan
59 F. App'x 622 (Sixth Circuit, 2003)
Walker v. Mintzes
771 F.2d 920 (Sixth Circuit, 1985)

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Benton v. Joyner, Counsel Stack Legal Research, https://law.counselstack.com/opinion/benton-v-joyner-kyed-2022.