Brown v. Talley

CourtDistrict Court, E.D. Virginia
DecidedJanuary 23, 2023
Docket1:21-cv-00703
StatusUnknown

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

Bluebook
Brown v. Talley, (E.D. Va. 2023).

Opinion

IN THE UNITED STATES DISTRICT COURT FOR THE EASTERN DISTRICT OF VIRGINIA Alexandria Division

Enoch Brown, ) Plaintiff, ) v. 1:21¢v703 (AJT/JFA) Kevin Talley, ef ai., Defendants. ) MEMORANDUM OPINION Plaintiff, a Virginia inmate, submitted this pro se action to redress alleged violations of his constitutional rights. [Dkt. No. 1]. This matter is before the Court on Defendant Colonel Larry Leabough’s (“Colonel Leabough”) Motion for Summary Judgment. [Dkt. No. 20]. For the reasons explained below, Colonel Leabough’s motion will be granted. IL Relevant Background and Procedural History By Order entered on October 19, 2021, the Court, inter alia, screened Plaintiff's Complaint pursuant to 28 U.S.C. § 1915A. [Dkt. No. 8]. In its screening Order, the Court concluded that the initial Complaint stated a due process claim against Colonel Leabough but dismissed Plaintiff's claims against two other Defendants. [/d.] The Court provided Plaintiff an opportunity to file an amended complaint to resurrect the dismissed claims. [See id.]. Thereafter, Plaintiff filed an Amended Complaint; however, by Order entered on January 5, 2022, the Court determined that Plaintiff's Amended Complaint did not state a claim for relief against any Defendant. [Dkt. No. 13 at 1]. Accordingly, the Court dismissed the Amended Complaint but permitted the due process claim against Colonel Leabough in the original Complaint to proceed and directed service on Colonel Leabough. [See id. at 1, The Court also noted in its January 5, 2022 Order that the posture of this case is somewhat

Colonel Leabough filed his Motion for Summary Judgment on March 9, 2022, which includes a proper notice pursuant to Roseboro v. Garrison, 528 F.2d 309 (4th Cir. 1975), advising Plaintiff of his right to respond to the motion within twenty-one days. [Dkt. No. 20]. Plaintiff has not filed a Response in Opposition and the time to do so has lapsed. The Court has reviewed and considered Plaintiff's Complaint as well as Colonel Leabough’s Motion for Summary Judgment and Memorandum in Support, including all of the attached declarations and exhibits. Colonel Leabough’s Motion for Summary Judgment is ripe for adjudication. I. Overview of the Parties Plaintiff is a pretrial detainee who is incarcerated at Riverside Regional Jail (““RRJ”) in North Prince George, Virginia. [Dkt. No. | at 1, 6]. Colonel Leabough is the Superintendent of RRJ and has served in that capacity since July 2020. Leabough Decl. at 1, [Dkt. No. 21-7 at 1-3]. Hi. Factual Background A. Plaintiffs Allegations” Plaintiff claims that when he arrived at RRJ on March 4, 2021, he was placed in “solitary confinement” at Colonel Leabough’s direction and pursuant to Colonel Leabough’s “SHU Life” policy, which allegedly mandates that an inmate who assaults a staff member is required to remain

unusual “given that an amended complaint typically supersedes a previously filed complaint.” [Dkt. No. 13 at 1 n.1]. As the Court previously explained, however, because none of the claims in the Amended Complaint survived the screening requirements of § 1915A, the Court, in deference to Plaintiff's pro se status, determined that the due process claim against Colonel Leabough in the initial Complaint would be permitted to go forward, and that the initial Complaint, [Dkt. No. 1], would be the operative Complaint in this action. [See id.]. ? Plaintiff's Complaint is not verified or sworn to under penalty of perjury. [Dkt. No. 1 at 1-6]. Thus, Plaintiff's Complaint is not admissible evidence and will not be considered in the Court’s analysis of the Colonel Leabough’s Motion for Summary Judgment. See McClellan v. Lewis, No. 3:08cv260, 2009 WL 2434141, at *2 (E.D. Va. Aug. 6, 2009) (explaining that an “unswom complaint ... is not competent summary judgment evidence”). However, the Court summarizes the relevant allegations of Plaintiff's Complaint herein to provide additional background of the basis for Plaintiff's claims. The Court also corrects the spelling, capitalization, and grammatical errors in the references to Plaintiff's Complaint.

in solitary confinement for the duration of his incarceration at RRJ. [Dkt. No. | at 5]. Plaintiff further claims that he was placed in “solitary confinement without a charge, or any periodic reviews” in violation of his Eighth and Fourteenth Amendment rights.’ [/d.]. B. Evidence Regarding RRJ’s Housing Classification System Inmates at RRJ are housed in accordance with an administrative classification system that balances a number of factors, including “the seriousness of the [inmate’s] current charges, any prior criminal offenses or escape attempts, and the inmate’s institutional disciplinary history.” [Dkt. No. 21 at 2] (citing Mack Decl. 43, [Dkt. No. 21-6 at 1-5]). Under this system, inmates may be housed in general population or in “alternative housing areas, including maximum security custody, protective custody, or the mental health pod.” Mack Decl. { 3; Leabough Decl. § 3, [Dkt. No. 21-7 at 1-3]. Assignments to housing areas are “made to ensure the safety of other inmates, RRJ staff, and the inmate himself.” Mack Decl. □ 3. The Restrictive Housing Unit (“RHU”) is a specialized housing unit for inmates who cannot be housed in general population due to safety or other concerns. id, 45. The RHU houses various classifications of inmates, including: (i) “those in restricted confinement,” also known as “administrative detention”; (ii) “those in disciplinary detention”; and (iii) “those in pre-hearing detention awaiting resolution of a disciplinary charge.” /d. Inmates who are housed in restricted confinement/administrative detention, are placed there on the basis of an “administrative decision primarily to address security concerns.” /d. J 7. In determining whether an inmate should be placed in administrative detention, RRJ staff evaluate several factors, such as “the inmate’s history of disciplinary violations, possession of contraband,

3 The Court notes that Plaintiff submitted a letter dated August 17, 2022, in which Plaintiff alleges that Colonel Leabough violated the terms of a May 23, 2002 “Behavior Contract” with Plaintiff. [Dkt No. 23]. To the extent that Plaintiff seeks to amend his Complaint to include this claim, such request is denied. Plaintiff is advised that, should he choose to do so, he may pursue this claim in a separate civil action.

[and] assaultive conduct, or other incidents that threaten security.” /d. A “Restrictive Housing Review Committee meets weekly to review each inmate housed in restricted confinement in the RHU to consider whether an inmate can be moved back into the general population, or whether he should be allowed additional privileges or fewer restrictions.” /d. The conditions of confinement for inmates housed in administrative detention “vary based on the security interests” that caused the inmate to be placed there. RRJ policy directs that classification personnel meet with inmates during this review process and any inmate who is dissatisfied with the Committee’s determinations may appeal. [See Dkt. No. 21-7 at 12] (RRJ restrictive housing policy stating that “[c]lassification personnel will meet with the inmate” during the review process); see also, Spratley Decl. § 3, [Dkt. No. 21-1] (noting that inmates “may appeal a [c]lassification or housing assignment”); Mack Decl. {7 (noting that inmates may appeal an assignment to restricted confinement). Inmates are placed in disciplinary detention if they are found to have violated disciplinary policies. See Mack Decl. § 4.

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Brown v. Talley, Counsel Stack Legal Research, https://law.counselstack.com/opinion/brown-v-talley-vaed-2023.