Clem v. Staley

CourtDistrict Court, E.D. Arkansas
DecidedOctober 13, 2021
Docket4:21-cv-00887
StatusUnknown

This text of Clem v. Staley (Clem v. Staley) 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
Clem v. Staley, (E.D. Ark. 2021).

Opinion

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

NEIL CLEM, PLAINTIFF #25946-009

v. 4:21CV00887-DPM-JTK

JOHN STALEY, et al. DEFENDANTS

ORDER Neil Clem (“Plaintiff”) is an inmate at the Lonoke County Detention Center. He filed this pro se action under 42 U.S.C. ' 1983 against Lonoke County Sheriff John Staley and Lonoke County Detention Center Administrator Kristi Flud. (Doc. No. 2). This Court granted Plaintiff’s Motion to Proceed in forma pauperis on October 12, 2021. (Doc. No. 3). The Court will now screen Plaintiff’s claims pursuant to the Prison Litigation Reform Act (“PLRA”). I. Screening The PLRA 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 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). An action is frivolous if “it lacks an arguable basis either in law or in fact.” Neitzke v. Williams, 490 U.S. 319, 325 (1989). Whether a plaintiff is represented by counsel or is appearing pro se, his complaint must allege specific facts sufficient to state a claim. See Martin v. Sargent, 780 F .2d 1334, 1337 (8th Cir.1985). An action fails to state a claim upon which relief can be granted if it does not plead “enough facts to state a claim to relief that is plausible on its face.” Bell Atlantic Corp. v. Twombly, 550 U.S. 544, 570 (2007). In reviewing a pro se complaint under ' 1915(e)(2)(B), the Court must give the complaint the benefit of a liberal construction. Haines v. Kerner, 404 U.S. 519, 520 (1972).

The Court must also weigh all factual allegations in favor of the plaintiff, unless the facts alleged are clearly baseless. Denton v. Hernandez, 504 U.S. 25, 32 (1992). II. Facts and Analysis Plaintiff sued Defendants in their official capacities only. (Doc. No. 2 at 4). Plaintiff alleges unlawful conditions of confinement. He alleges that inmates are not being given toothpaste, a toothbrush, deodorant, soap, or clean linens. (Id. at 6). Plaintiff also claims inmates “are being forced to live . . . with an [inadequate] number of working toilets or sinks.” (Id.) He claims one toilet has “toxic sludge” in it, and “sewer gas coming out of it.” (Id.) According to Plaintiff, inmates are forced to inhale the sewer gas, “making [them] sick.” (Id.) Plaintiff further alleges the meal trays retain water in holes and are never drained; the

stagnant water contaminates inmates’ food. (Id. at 7). Plaintiff claims that as a result of the water contaminating food, two inmates have been sent to the hospital with hepatitis A. (Doc. No. 2 at 7). According to Plaintiff, inmate personal and legal mail “is stacking up and not being sorted and passed out.” (Id. at 7). Plaintiff says that on September 26, 2021, inmates are receiving mail postmarked August 30, 2021. Lastly, Plaintiff complains that “[t]here is no grievance procedure here at this Jail.” (Id.) More precisely, Plaintiff says there is no “neutral officer” at the Detention Center to deal with inmate issues, and that any grievance appeals go to the same person who considered the grievance initially—Defendant Flud. (Id.) Plaintiff states that if inmates have a problem, “nobody of power . . . [ever] get[s] the grievance, it never goes over [Defendant Flud’s] head.” (Id.) Plaintiff specified that the “Sheriffs” never receive inmate complaints. (Id.) Plaintiff “want[s] a class action law suit”1 and damages, among other relief. (Doc. No. 2

at 8). A. Class Action As mentioned above, Plaintiff wishes for this lawsuit to proceed as a class action. Pro se litigants are not authorized to represent the rights, claims and interests of other parties in any cause of action, including a class action lawsuit. Fymbo v. State Farm Fire and Cas. Co., 213 F.3d 1320, 1321 (10th Cir. 2000) (“A litigant may bring his own claims to federal court without counsel, but not the claims of others”); Oxendine v. Williams, 509 F.2d 1405, 1407 (4th Cir. 1975); cf. Knoefler v. United Bank of Bismarck, 20 F.3d 347, 348 (8th Cir. 1994) (“A nonlawyer . . . has no right to represent another entity.”). To the extent Plaintiff brought claims on behalf of a class, those claims fail.

B. Sheriff John Staley Plaintiff named John Staley as a Defendant, but made no allegations against him. On the contrary, in his Complaint Plaintiff stated that “the Sheriffs” never learn of inmate issues. (Doc. No. 2 at 7). Because Plaintiff not only made no factual allegations against Defendant Staley, but represented that Defendant Staley has no knowledge of the issues facing inmates, Plaintiff’s allegations against Defendant Staley fail to state a claim on which relief may be granted.

1 Plaintiff is one of 16 individuals who signed the Complaint. The multi-Plaintiff action was opened as individual cases. C. Delayed Mail Plaintiff alleges inmates’ legal and personal mail is “stacking up and not being sorted out.” (Doc. No. 2 at 7). Plaintiff has not alleged any restrictions on mail, censorship of mail, etc.—only delay.

Legal mail is narrowly defined as “mail to or from an inmate’s attorney and identified as such.” Gardner v. Howard, 109 F.3d 427, 430 (8th Cir. 1997). It is unclear from Plaintiff’s Complaint if the mail to which he refers is privileged legal mail. Because Plaintiff has not alleged the mail in question was mail from his attorney, the Court interprets Plaintiff’s claim as falling under the First Amendment, rather than the Sixth Amendment. See Wolff v. McDonnell, 418 U.S. 529, 576-77 (1974). To state a First Amendment claim, a plaintiff must allege actual injury – in an access to the courts claim the injury would be “the hindrance of a nonfrivolous and arguable meritorious underlying legal claim” Hartsfield v. Nichols, 511 F.3d 826, 831 (8th Cir. 2008). Plaintiff has not alleged any harm from the purported delay in receiving mail. Accordingly, Plaintiff failed to state

a First Amendment claim in connection with his delayed mail. D. Grievance Policy Plaintiff complains that the grievance procedure at the Detention Center is ineffective. (Doc. No. 2 at 6). There is, however, no constitutional right to a grievance procedure. See Buckley v. Barlow, 997 F.2d 494, 495 (8th Cir. 1993). As such, no claim lies when a grievance receives no response or yields no result. See Id. Accordingly, Plaintiff’s allegations concerning the grievance procedure fail to state a claim. E. Conditions of Confinement A pretrial detainee’s conditions of confinement claim is governed by the standard set out by the United States Supreme Court in Bell v. Wolfish, 441 U.S. 520 (1979). Stearns v. Inmate Services Corp., 957 F.3d 902, 907-08 (8th Cir. 2020).

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Related

Haines v. Kerner
404 U.S. 519 (Supreme Court, 1972)
Warth v. Seldin
422 U.S. 490 (Supreme Court, 1975)
Bell v. Wolfish
441 U.S. 520 (Supreme Court, 1979)
Allen v. Wright
468 U.S. 737 (Supreme Court, 1984)
Neitzke v. Williams
490 U.S. 319 (Supreme Court, 1989)
Denton v. Hernandez
504 U.S. 25 (Supreme Court, 1992)
Bell Atlantic Corp. v. Twombly
550 U.S. 544 (Supreme Court, 2007)
Fymbo v. State Farm Fire & Casualty Co.
213 F.3d 1320 (Tenth Circuit, 2000)
Oxendine v. Williams
509 F.2d 1405 (Fourth Circuit, 1975)
Buckley v. Barlow
997 F.2d 494 (Eighth Circuit, 1993)
Gardner v. Howard
109 F.3d 427 (Eighth Circuit, 1997)
Hartsfield v. Nichols
511 F.3d 826 (Eighth Circuit, 2008)
Hodak v. City of St. Peters
535 F.3d 899 (Eighth Circuit, 2008)
Danzel Stearns v. Inmate Services Corporation
957 F.3d 902 (Eighth Circuit, 2020)
Knoefler v. United Bank of Bismarck
20 F.3d 347 (Eighth Circuit, 1994)

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Bluebook (online)
Clem v. Staley, Counsel Stack Legal Research, https://law.counselstack.com/opinion/clem-v-staley-ared-2021.