Bryant v. James T. Vaughn Correctional Center

CourtDistrict Court, D. Delaware
DecidedMarch 17, 2025
Docket1:24-cv-00207
StatusUnknown

This text of Bryant v. James T. Vaughn Correctional Center (Bryant v. James T. Vaughn Correctional Center) is published on Counsel Stack Legal Research, covering District Court, D. Delaware primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Bryant v. James T. Vaughn Correctional Center, (D. Del. 2025).

Opinion

IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF DELAWARE

JONATHAN WHITNEY BRYANT, ) ) Plaintiff, ) ) v. ) C.A. No. 24-207-CFC-EGT ) JAMES T. VAUGHN CORRECTIONAL ) CENTER et al., ) ) Defendants. )

REPORT AND RECOMMENDATION

Plaintiff Jonathan Whitney Bryant, an inmate at James T. Vaughn Correction Center (“JTVCC”), filed this action pursuant to 42 U.S.C. § 1983. (D.I. 1). Plaintiff appears pro se and has been granted leave to proceed in forma pauperis. (D.I. 6). The Court proceeds to screen the Complaint pursuant to 28 U.S.C. §§ 1915(e)(2)(B) and 1915A(a). For the reasons set forth below, the Court recommends that the claims against Sergeant Carter, Correctional Officer Banya and Correctional Officer Jolly be DISMISSED WITHOUT PREJUDICE. The Court further recommends that the claim against JTVCC be DISMISSED WITH PREJUDICE. I. BACKGROUND According to the Complaint, Plaintiff attempted to mail an envelope addressed to “CDBaby.com” on the morning of January 13, 2024. (D.I. 1 at 5). Plaintiff handed the envelope to Correctional Officer Jolly, with Sergeant Carter present. (Id.). Later that same day, Plaintiff spoke with Correctional Officer Banya, who told Plaintiff that he found his letter and that next time he should mail it out during the 4-12 p.m. shift. (Id.). Despite CDBaby.com usually only taking a few days to respond, Plaintiff had received no response by February 9, 2024. (Id. at 5). The envelope apparently contained business information between CDBaby.com and Plaintiff, as well as some of Plaintiff’s personal information. (Id. at 6). Plaintiff alleges that his mail is “missing” between Correctional Officers Jolly and Banya. (Id.). Although there is a grievance procedure at JTVCC, Plaintiff claims that he did not file a grievance concerning the alleged conduct because he was afraid. (D.I. 1 at 8). Plaintiff instead

filed the present Complaint, which was docketed on February 15, 2024. (Id. at 11). II. LEGAL STANDARDS A federal court may properly dismiss an action sua sponte under the screening provisions of 28 U.S.C. §§ 1915(e)(2)(B) and 1915A if “the action 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.” Ball v. Famiglio, 726 F.3d 448, 452 (3d Cir. 2013) (quotation marks omitted); see also 28 U.S.C. § 1915(e)(2) (in forma pauperis actions); 28 U.S.C. § 1915A (civil actions filed by prisoners seeking redress from governmental entities or government officers and employees). The Court must accept all factual allegations in a complaint as true and view them in the light most favorable to a pro se plaintiff. See Phillips v. County of Allegheny, 515 F.3d 224, 229 (3d Cir. 2008). Because Plaintiff proceeds pro se, his pleading is liberally construed and his Complaint,

“however inartfully pleaded, must be held to less stringent standards than formal pleadings drafted by lawyers.” Erickson v. Pardus, 551 U.S. 89, 94 (2007). A complaint is not automatically frivolous because it fails to state a claim. See Dooley v. Wetzel, 957 F.3d. 366, 374 (3d Cir. 2020). Rather, a claim is deemed frivolous only where it relies on an “‘indisputably meritless legal theory’ or a ‘clearly baseless’ or ‘fantastic or delusional’ factual scenario.’” Id. The legal standard for dismissing a complaint for failure to state a claim pursuant to §§ 1915(e)(2)(B)(ii) and 1915A(b)(1) is identical to the legal standard used when ruling on Rule 12(b)(6) motions. Tourscher v. McCullough, 184 F.3d 236, 240 (3d Cir. 1999). Before dismissing a complaint or claims for failure to state a claim upon which relief may be granted pursuant to the screening provisions of 28 U.S.C. §§ 1915 and 1915A, however, the Court must grant Plaintiff leave to amend his complaint unless amendment would be inequitable or futile. See Grayson v. Mayview State Hosp., 293 F.3d 103, 114 (3d Cir. 2002).

A well-pleaded complaint must contain more than mere labels and conclusions. See Ashcroft v. Iqbal, 556 U.S. 662 (2009); Bell Ad. Corp. v. Twombly, 550 U.S. 544 (2007). A plaintiff must plead facts sufficient to show that a claim has substantive plausibility. See Johnson v. City of Shelby, 574 U.S. 10, 12 (2014). A complaint may not be dismissed, however, for imperfect statements of the legal theory supporting the claim asserted. See id. at 11. A court reviewing the sufficiency of a complaint must take three steps: (1) take note of the elements the plaintiff must plead to state a claim; (2) identify allegations that, because they are no more than conclusions, are not entitled to the assumption of truth; and (3) when there are well- pleaded factual allegations, assume their veracity and then determine whether they plausibly give rise to an entitlement to relief. Connelly v. Lane Constr. Corp., 809 F.3d 780, 787 (3d Cir. 2016).

Elements are sufficiently alleged when the facts in the complaint “show” entitlement to relief. Iqbal, 556 U.S. at 679 (quoting FED. R. CIV. P. 8(a)(2)). Determining whether a claim is plausible is a “context-specific task that requires the reviewing court to draw on its judicial experience and common sense.” Id. III. DISCUSSION A. Claims Against Defendants Carter, Banya and Jolly Prisoners have a First Amendment right to send and receive mail. See Jones v. Brown, 461 F.3d 353, 358 (3d Cir. 2006). That being said, courts have generally held that “a single, isolated interference with . . . personal mail [is] insufficient to constitute a First Amendment violation.” Nixon v. Sec’y Pa. Dep’t of Corr., 501 F. App’x 176, 178 (3d Cir. 2012); see also Bieregu v. Reno, 59 F.3d 1445, 1452 (3d Cir. 1995) (“We decline to hold that a single instance of damaged mail rises to the level of constitutionally impermissible censorship.”), abrogated on other grounds by Lewis v. Casey, 518 U.S. 343 (1996); see also Davis v. Goord,

Related

Lewis v. Casey
518 U.S. 343 (Supreme Court, 1996)
Erickson v. Pardus
551 U.S. 89 (Supreme Court, 2007)
Bell Atlantic Corp. v. Twombly
550 U.S. 544 (Supreme Court, 2007)
Ashcroft v. Iqbal
556 U.S. 662 (Supreme Court, 2009)
Wayne Baker v. James T Vaughn Correctional Ce
425 F. App'x 83 (Third Circuit, 2011)
Davis v. Goord
320 F.3d 346 (Second Circuit, 2003)
Nixon v. Secretary Pennsylvania Department of Corrections
501 F. App'x 176 (Third Circuit, 2012)
Dawn Ball v. Famiglio
726 F.3d 448 (Third Circuit, 2013)
Phillips v. County of Allegheny
515 F.3d 224 (Third Circuit, 2008)
Williams v. Frame
821 F. Supp. 1093 (E.D. Pennsylvania, 1993)
Jones v. Brown
461 F.3d 353 (Third Circuit, 2006)
Sandra Connelly v. Lane Construction Corp
809 F.3d 780 (Third Circuit, 2016)
Casey Dooley v. John Wetzel
957 F.3d 366 (Third Circuit, 2020)
Sincavage v. Barnhart
171 F. App'x 924 (Third Circuit, 2006)
Henderson v. Carlson
812 F.2d 874 (Third Circuit, 1987)

Cite This Page — Counsel Stack

Bluebook (online)
Bryant v. James T. Vaughn Correctional Center, Counsel Stack Legal Research, https://law.counselstack.com/opinion/bryant-v-james-t-vaughn-correctional-center-ded-2025.