Bullard v. Shaw

CourtDistrict Court, E.D. Arkansas
DecidedJuly 20, 2023
Docket4:23-cv-00523
StatusUnknown

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

Bluebook
Bullard v. Shaw, (E.D. Ark. 2023).

Opinion

IN THE UNITED STATES DISTRICT COURT EASTERN DISTRICT OF ARKANSAS CENTRAL DIVISION

TRAVELES D. BULLARD PLAINTIFF ADC #131228

V. NO. 4:23-cv-00523-JM-ERE

ALYSIA SHANTRELLE SHAW, et al. DEFENDANTS

RECOMMENDED DISPOSITION

I. Procedure for Filing Objections: This Recommendation has been sent to United States District Judge James M. Moody Jr. You may file written objections to all or part of this Recommendation. Any objections filed must: (1) specifically explain the factual and/or legal basis for the objection; and (2) be received by the Clerk of this Court within fourteen (14) days of the date of this Recommendation. If you do not object, you risk waiving the right to appeal questions of fact and Judge Moody can adopt this Recommendation without independently reviewing the record. II. Background: Plaintiff Traveles D. Bullard, an Arkansas Division of Correction (“ADC”) inmate, filed this civil rights lawsuit pro se under 42 U.S.C. § 1983. Doc. 1. Mr. Bullard’s original complaint alleged that Defendants violated his due process rights by falsifying a disciplinary charge against him. He sued Sergeant Alysia Shantrelle Shaw, Lieutenant Rodney Henderson, Warden Todd Ball, and ADC Director Dexter Payne and requested injunctive relief.1 The Court previously determined that Mr. Bullard’s complaint failed to state

a plausible constitutional claim. Doc. 4. In addition, Mr. Bullard failed to sign his original complaint. However, rather than screen the original complaint and recommend dismissal, the Court postponed the screening process2 to give Mr.

Bullard an opportunity to file an amended complaint clarifying his constitutional claims. Mr. Bullard has now filed a signed, amended complaint. Doc. 5. For the reasons explained below, Mr. Bullard’s claims should be dismissed, without prejudice, based on his failure to state a plausible constitutional claim for relief.

III. Discussion: A. Standard To survive § 1915A screening, a “complaint must contain sufficient factual

matter, accepted as true, to state a claim to relief that is plausible on its face.”

1 Mr. Bullard requested that the Court order ADC officials to: (1) perform a stress test; (2) restore his good time; (3) restore his visitation rights; (3) restore his classification status; (4) transfer him to another ADC unit; and (5) terminate the employment of all ADC officials involved in the underlying incident. Doc. 1 at 6.

2 Screening is mandated by the Prison Litigation Reform Act, which requires federal courts to screen prisoner complaints seeking relief against a governmental entity, officer, or employee. 28 U.S.C. § 1915A(a). The Court must dismiss a complaint or a portion thereof if the prisoner has raised claims that: (a) are legally frivolous or malicious; (b) fail to state a claim upon which relief may be granted; or (c) seek monetary relief from a defendant who is immune from such relief. 28 U.S.C. § 1915A(b). When making this determination, the Court must accept the truth of the factual allegations contained in the complaint, and it may consider the documents attached to the complaint. Ashcroft v. Iqbal, 556 U.S. 662, 678 (2009); Reynolds v. Dormire, 636 F.3d 976, 979 (8th Cir. 2011). Ashcroft v. Iqbal, 556 U.S. 662, 678 (2009) (explaining that “labels and conclusions,” a “formulaic recitation of the elements of a cause of action,” and

“naked assertions devoid of further factual enhancement” are insufficient to plead a § 1983 claim; and instead, a prisoner must set forth “sufficient factual matter, accepted as true, to state a claim to relief that is plausible on its face”); see also Bell

Atlantic Corp. v. Twombly, 550 U.S. 544, 555-56 (2007). B. Mr. Bullard’s Allegations In his amended complaint, Mr. Bullard alleges that Defendant Shaw falsified a disciplinary against him for allegedly refusing to be drug tested. Doc. 5. He also

complaints that Defendant Shaw allegedly refused to sign the major disciplinary in violation of ADC policy. Mr. Bullard alleges that such conduct violates: (1) the Fourteenth Amendment; and (2) the Universal Declaration of Human Rights Act. In

addition, he alleges that, because Defendant Shaw had knowledge that he was “fully exposed to[] adult maltreatment intentional and unnecessary cruel and unusual punishment by be[ing] housed in restrictive housing for 25 days,” she was required to report this conduct under the Long Term Care Facility Resident Maltreatment Act,

ARK. CODE. ANN. § 12-12-1708. Id. at 8. C. Due Process Claim To state a Fourteenth Amendment due process claim, a prisoner “must first

demonstrate that he was deprived of life, liberty, or property by government action.” See Phillips v. Norris, 320 F.3d 844, 846 (8th Cir. 2003). Here, the due process claim must be based on the denial of a liberty interest.

In his amended complaint, Mr. Bullard states that, as a result of the conviction for the disciplinary charge at issue, he was assigned to restrictive housing for 25 days. Doc. 5 at 8. Such punishment is not severe enough to trigger a liberty interest.

See Thornsberry v. Barden, 854 F. App’x 105 (8th Cir. 2021) (“Thornsberry’s assignment to isolation, loss of privileges, and reclassification were insufficient to state a due process claim.”); Orr v. Larkins, 610 F.3d 1032, 1034 (8th Cir. 2010) (inmate not deprived of liberty interest during nine months in administrative

segregation); Portley-El v. Brill, 288 F.3d 1063, 1065-66 (8th Cir. 2002) (inmates have no liberty interest in maintaining a particular classification level; and thirty days in punitive segregation is not an atypical and significant hardship); and

Kennedy v. Blankenship, 100 F.3d 640, 642-43 & n.2 (8th Cir. 1996) (placement in punitive isolation was not atypical and significant hardship despite restrictions in mail, telephone, visitation, commissary, and property privileges). Accordingly, Mr. Bullard has failed to state a plausible constitutional claim for relief.

D. Violation of ADC Policy To the extent that Mr. Bullard alleges that Defendant Shaw violated ADC policy by failing to sign the major disciplinary at issue, this claim also fails. The law

is settled that failing to follow prison policies or procedures is not conduct that rises to the level of a constitutional claim. McClinton v. Arkansas Dep’t of Corr., 166 Fed. Appx. 260 (8th Cir. 2006) (citing Kennedy v. Blankenship, 100 F.3d 640, 643 (8th

Cir. 1996)). E. Violation of Universal Declaration of Human Rights Act It is unclear what possible application the Universal Declaration of Human Rights (Declaration), a United Nations General Assembly proclamation from 1948,3

could possibly have to Mr. Bullard’s allegations in this lawsuit. In any event, Mr. Bullard has no right to bring a civil suit in federal court to either enforce the Declaration or to seek a remedy for its alleged violation. See Sosa v. Alvarez-

Machain, 542 U.S. 692, 734-35 (2004). F.

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Related

Sosa v. Alvarez-Machain
542 U.S. 692 (Supreme Court, 2004)
Bell Atlantic Corp. v. Twombly
550 U.S. 544 (Supreme Court, 2007)
Ashcroft v. Iqbal
556 U.S. 662 (Supreme Court, 2009)
Orr v. Larkins
610 F.3d 1032 (Eighth Circuit, 2010)
Reynolds v. Dormire
636 F.3d 976 (Eighth Circuit, 2011)
Brother Patrick Portley-El v. Hoyt Brill
288 F.3d 1063 (Eighth Circuit, 2002)
Clemmons v. Armontrout
477 F.3d 962 (Eighth Circuit, 2007)
McClinton v. Arkansas Department of Correction
166 F. App'x 260 (Eighth Circuit, 2006)

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