Briggs v. Rhode Island Department of Corrections

CourtDistrict Court, D. Rhode Island
DecidedSeptember 29, 2025
Docket1:22-cv-00031
StatusUnknown

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

Bluebook
Briggs v. Rhode Island Department of Corrections, (D.R.I. 2025).

Opinion

UNITED STATES DISTRICT COURT FOR THE DISTRICT OF RHODE ISLAND

___________________________________ ) SIMEON BRIGGS, ) ) Plaintiff, ) ) v. ) C.A. No. 22-31 WES ) LINDA AMADO, ) ) Defendant. ) ___________________________________)

MEMORANDUM AND ORDER

WILLIAM E. SMITH, Senior District Judge. Before the Court are Plaintiff’s Motion for Summary Judgment (“Plaintiff’s Motion”), Dkt. No. 144, and “Defendant’s, Linda Amado, Motion for Summary Judgment” (“Defendant’s Motion”), Dkt. No. 160. The Court finds that no hearing is necessary. For the following reasons, Plaintiff’s Motion is DENIED and Defendant’s Motion is GRANTED. I. BACKGROUND In 2003, Plaintiff Simeon Briggs began serving a life sentence for first-degree murder at the Rhode Island Department of Corrections (“RIDOC”). Statement of Undisputed Facts Precluding Pl.’s Mot. (“DSUF”) ¶ 30, Dkt. No. 186. While in RIDOC custody, Briggs committed dozens of disciplinary infractions, including a 2009 gang-related assault for which he is serving a consecutive, twenty-year sentence, and in 2012, he was transferred to the Federal Bureau of Prisons (the “FBOP”). Id. ¶¶ 31-39; see id. Ex. N, Dkt. No. 186-14. On December 9, 2019, the FBOP sent RIDOC’s Classification Office a letter requesting that RIDOC retake custody of Briggs, as it was “unable to continue to house him due to his extensive management concerns.” Id. ¶¶ 40-41; see id. Ex. G, Dkt. No. 186-

7. Rather than retake custody of Briggs, RIDOC sought to arrange his transfer from the FBOP to “correctional institutions outside of Rhode Island,” which it believed “were better suited to provide [him] with an opportunity for placement in a less restrictive setting.” Id. ¶¶ 42-44. RIDOC therefore sent a transfer package for Briggs to fellow member states of the Interstate Corrections Compact and, on January 10, 2020, the Virginia Department of Corrections (“VADOC”) sent a letter to RIDOC stating that it would accept his transfer. Id. ¶¶ 43, 45-46; see id. Ex. H, Dkt. No. 186-8; see also id. ¶¶ 27-28; id. Ex. A, Dkt. No. 186-1. RIDOC had thirty days upon receipt of the FBOP’s December 9 letter to retake custody of Briggs or coordinate his transfer to

another location. Id. ¶¶ 52; see also id. Ex. A, at 12. Because RIDOC was unable to coordinate Briggs’s transfer from the FBOP to VADOC within that timeframe, RIDOC retook custody of Briggs on January 17, 2020. Id. ¶¶ 47-54. Soon thereafter, “RIDOC placed an indefinite pause on interstate transfers due to Covid-19.” Id. 2 ¶ 55. RIDOC “intended to effectuate VADOC’s acceptance . . . when transfers resumed.” Id. ¶ 56. A year after Briggs returned to RIDOC — on January 20, 2021 — “VADOC requested updated discipline and mental health records for [Briggs].” Id. ¶ 57. “At this time, RIDOC had resumed interstate transfers.” Id. ¶ 58. But then, on

February 1, 2021, VADOC rescinded its acceptance of the transfer request after a “large-scale assault” in one of its facilities affected its available bedspace. Id. ¶ 59. RIDOC therefore sent Briggs’s transfer package to other members of the Interstate Corrections Compact. Id. ¶ 60. This proved unnecessary, however, because on May 25, 2021, VADOC reinstated its acceptance of Briggs’s transfer. Id. ¶ 61; see id. Ex. I, Dkt. No. 186-9. After receiving a Notice of Involuntary Transfer from RIDOC dated June 8, 2021, Briggs was transferred to VADOC on a noncommercial flight. Id. ¶ 62, see id. Ex. J, Dkt. No. 186-10; see also id. ¶ 51. In the seventeen months he was at RIDOC before his transfer to VADOC, Briggs was found guilty of ten disciplinary infractions, id. ¶¶ 79-

82; see id. Ex. L, Dkt. No. 186-12, and he was housed in RIDOC’s High Security Center the entire time, id. ¶ 83; see id. Ex. P, Dkt. No. 186-16. Briggs has since returned to RIDOC custody. Id.

3 ¶ 84. * * * Briggs challenged his transfer to VADOC in a pro se Complaint filed in this Court on January 20, 2022. Compl., Dkt. No. 1. He has since successfully amended his Complaint twice, and the Court has since dismissed all but one of his claims. See Am. Compl.,

Dkt. No. 3; 2d Am. Compl., Dkt. No. 15; Text Order (Sep. 6, 2022); Text Order (Oct. 4, 2023). Briggs’s sole remaining claim is that Defendant Linda Amado, RIDOC’s Administrator of Classification Services, violated his First Amendment rights by transferring him to VADOC in retaliation for filing grievances against RIDOC staff. Text Order (Sep. 6, 2022); see 2d Am. Compl. ¶¶ 28, 35, 37-39. This claim is now before the Court on the parties’ motions for summary judgment. Pl.’s Mot.; Def.’s Mot; see also Order 3, Dkt. No. 177 (denying Plaintiff’s Motion in part and reserving on his First Amendment claim); Order 6, Dkt. No. 178 (reserving on Defendant’s Motion).

II. LEGAL STANDARD “A grant of summary judgment is appropriate when ‘there is no genuine dispute as to any material fact and the movant is entitled to judgment as a matter of law.’” Viscito v. Nat’l Planning Corp., 34 F.4th 78, 83 (1st Cir. 2022) (quoting Garcia-Garcia v. Costco Wholesale Corp., 878 F.3d 411, 417 (1st Cir. 2017)). “A genuine 4 issue of fact exists where the evidence is such that a reasonable jury could return a verdict for the nonmoving party.” Id. (quoting Garcia-Garcia, 878 F.3d at 417). “The court must examine the record in the light most favorable to the nonmovant and must make all reasonable inferences in that party’s favor.” Id. (quoting Garcia-Garcia, 878 F.3d at 417) (internal quotation marks

omitted). “That both plaintiff[] and defendant moved for summary judgment does not change the underlying standard; [the court] simply determine[s] whether either side deserves judgment as a matter of law on the undisputed facts.” Modeski v. Summit Retail Sols., Inc., 27 F.4th 53, 56 (1st Cir. 2022). “[E]ach motion is reviewed separately, drawing facts and inferences in favor of the non-moving party.” Scottsdale Ins. v. United Rentals (N. Am.), Inc., 977 F.3d 69, 72 (1st Cir. 2020). III. DISCUSSION Briggs filed his First Amendment retaliation claim against Amado under 42 U.S.C. § 1983. 2d Am. Compl. ¶¶ 1, 5. To succeed

on this claim, Briggs must “demonstrate that (1) he engaged in constitutionally protected conduct, (2) he suffered an adverse action, and (3) there was a causal connection between the constitutionally protected conduct and the adverse action.” Price v. Wall, 464 F. Supp. 2d 90, 96 (D.R.I. 2006). Regarding the third 5 element’s causation requirement, Briggs “must prove that he would not have been transferred ‘but for’ the alleged reason.” McDonald v. Hall, 610 F.2d 16, 18 (1st Cir. 1979). This “but-for” standard imposes a “substantial burden” on a plaintiff like Briggs, id., because “even if the defendant had an impermissible reason for the alleged adverse action, if a separate, permissible reason exists,

the defendant will not be liable,” Price, 464 F. Supp. 2d at 96; see also Sullivan v. Corr., Me. Warden, 96 F.3d 1430, at *1 (1st Cir. 1996) (“[I]f taken for both permissible and impermissible reasons, state action may be upheld if the action would have been taken based on permissible reasons alone.”). The first and second elements of Briggs’s retaliation claim are not contested.

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Related

Sullivan v. ME Warden
96 F.3d 1430 (First Circuit, 1996)
Anthony F. McDonald v. Frank A. Hall
610 F.2d 16 (First Circuit, 1979)
Price v. Wall
464 F. Supp. 2d 90 (D. Rhode Island, 2006)
Garcia-Garcia v. Costco Wholesale Corp.
878 F.3d 411 (First Circuit, 2017)
Modeski v. Summit Retail Solutions, Inc.
27 F.4th 53 (First Circuit, 2022)
Viscito v. National Planning Corporation
34 F.4th 78 (First Circuit, 2022)

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Briggs v. Rhode Island Department of Corrections, Counsel Stack Legal Research, https://law.counselstack.com/opinion/briggs-v-rhode-island-department-of-corrections-rid-2025.