Bumgardner-Lockamy v. Logan

District Court, W.D. North Carolina·Decided August 22, 2023·No. 1:23-cv-00061·Unknown

Opinion

IN THE UNITED STATES DISTRICT COURT FOR THE WESTERN DISTRICT OF NORTH CAROLINA ASHEVILLE DIVISION CIVIL CASE NO. 1:23-cv-00061-MR

ZACHARY BUMGARDNER- ) LOCKAMY,1 ) ) Plaintiff, ) ) vs. ) ) M. LOGAN, et al., ) ORDER ) Defendants. ) _______________________________ )

THIS MATTER is before the Court on initial review of the pro se Amended Complaint. [Doc. 10]. The Plaintiff is proceeding in forma pauperis. [Doc. 8]. I. BACKGROUND The pro se incarcerated Plaintiff filed this civil rights action pursuant to 42 U.S.C. § 1983 addressing incidents that allegedly occurred at the Rutherford County Jail (“RCJ”), where he is presently incarcerated. The Complaint was dismissed on initial review, and the Plaintiff was granted the

1 According to the North Carolina Department of Adult Corrections’ website, the Plaintiff’s name is Zachary Brandon Bumgardner. See https://webapps.doc.state.nc.us/opi/view offender.do?method=view&offenderID=1565545&searchLastName=bumgardner&searc hFirstName=zachary&searchDOBRange=0&listurl=pagelistoffendersearchresults&listpa ge=1 (last accessed Aug. 2, 2023); Fed. R. Evid. 201. opportunity to amend. [Doc. 9]. The Amended Complaint is now before the Court for initial review. [Doc. 10].

The Plaintiff again names as Defendants M. Logan, a correctional sergeant, and FNU Smith, a correctional corporal. [Id. at 2]. He reasserts his claim for denial of access to the courts, and he also asserts a new First Amendment claim for “communication with attorney(s).”2 [Id. at 3]. For

injury, he claims that “[he] was impeded from getting [his] attorneys information & [his] legal papers by filing that 20 day deadline for a civil matter in District Court.” [Id. at 5]. He seeks injunctive relief, and nominal and

punitive damages. [Id.]. II. STANDARD OF REVIEW Because the Plaintiff is proceeding in forma pauperis, the Court must

review the Amended Complaint to determine whether it is subject to dismissal on the grounds that it is “(i) frivolous or malicious; (ii) fails to state a claim on which relief may be granted; or (iii) seeks monetary relief against a defendant who is immune from such relief.” 28 U.S.C. § 1915(e)(2)(B); see

28 U.S.C. § 1915A (requiring frivolity review for prisoners’ civil actions seeking redress from governmental entities, officers, or employees).

2 The Amended Complaint is also liberally construed as raising a claim that the Plaintiff’s grievances were denied or ignored. In its frivolity review, a court must determine whether a complaint raises an indisputably meritless legal theory or is founded upon clearly

baseless factual contentions, such as fantastic or delusional scenarios. Neitzke v. Williams, 490 U.S. 319, 327-28 (1989). Furthermore, a pro se complaint must be construed liberally. Haines v. Kerner, 404 U.S. 519, 520

(1972). However, the liberal construction requirement will not permit a district court to ignore a clear failure to allege facts in his complaint which set forth a claim that is cognizable under federal law. Weller v. Dep’t of Soc. Servs., 901 F.2d 387 (4th Cir. 1990).

III. DISCUSSION The Plaintiff reasserts his claim that the Defendants deprived him of access to the courts. The Plaintiff claims that he had “a deadline on a packet”

that he had to fill out for his lawyer for “a legal proceeding,” and that he had “a legal paper that the State Bureau of Investigation sent [to him]” regarding his foster brother’s “case about his release.” [Doc. 10 at 13]. These allegations are too vague and conclusory to plausibly allege that the Plaintiff3

3 To the extent that the Plaintiff is attempting to assert a claim on behalf of his foster brother, he is not qualified to do so. See generally Myers v. Loudoun Cnty. Pub. Schls., 418 F.3d 395, 400 (4th Cir. 2005) (“An individual unquestionably has the right to litigate his own claims in federal court.... The right to litigate for oneself, however, does not create a coordinate right to litigate for others”); Hummer v. Dalton, 657 F.2d 621, 625 (4th Cir. 1981) (prisoner’s suit is “confined to redress for violations of his own personal rights and not one by him as knight-errant for all prisoners”); Oxendine v. Williams, 509 F.2d 1405, suffered any actual injury. [See Doc. 9 at 5-6]. Accordingly, this claim is dismissed for the reasons discussed in the Order on initial review of the

Complaint. [Id.]. The Plaintiff further claims that the Defendants violated the First Amendment when they failed to return to him a piece of “legal mail” following

a search of his property. [Doc. 10 at 12-13]. The Plaintiff alleges that this legal mail contained his attorney’s “information” and, without it, the Plaintiff was unable to “consult with an attorney or legal documents of an attorney….” [Id. at 12].

As a general matter, prisoners have the First Amendment right to both send and receive mail. See Thornburgh v. Abbott, 490 U.S. 401, 408 (1989); Pell v. Procunier, 417 U.S. 817 (1974). Restrictions on this right are valid if

they are reasonably related to legitimate penological interests. Turner v. Safley, 482 U.S. 78, 89 (1987); see Haze v. Harrison, 961 F.3d 654, 658 (4th Cir. 2020) (noting that Turner applies to both convicted prisoners and pretrial detainees). For instance, a prisoner’s First Amendment interest in

corresponding does not preclude prison officials from examining mail to ensure that it does not contain contraband. Wolff v. McDonnell, 418 U.S.

1407 (4th Cir. 1975) (“[I]t is plain error to permit [an] imprisoned litigant who is unassisted by counsel to represent his fellow inmates in a class action.”). 539, 576 (1974). “[L]egal mail is widely recognized to be privileged and confidential — even in the context of prisons — which suggests that an

incarcerated person’s expectation of privacy in his legal mail is one ‘that society is prepared to consider reasonable.’” Haze v. Harrison, 961 F.3d 654, 660 (4th Cir. 2020) (quoting United States v. Catellanos, 716 F.3d 828, 832 (4th Cir. 2013)); see King v. Rubenstein, 825 F.3d 206, 215 (4th Cir. 2016)

(“nothing in Hudson4 indicates the Supreme court intended to abrogate a prisoner’s expectation of privacy beyond his cell); Turner, 482 U.S. at 89 (prison restrictions impinging on an inmate’s constitutional rights are valid if

they are reasonably related to legitimate penological interests). Here, the Plaintiff’s claim that a piece of legal mail was not returned to him on a single occasion does not rise to the level of a constitutional violation. See Buie v. Jones, 717 F.2d 925, 926 (4th Cir.

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