Cotto v. Hendrix

District Court, N.D. Indiana·Decided August 22, 2025·No. 3:25-cv-00066·Unknown

Opinion

UNITED STATES DISTRICT COURT NORTHERN DISTRICT OF INDIANA SOUTH BEND DIVISION

DAVID COTTO,

Plaintiff,

v. CAUSE NO. 3:25-CV-66-JD-JEM

JACK HENDRIX, et al.,

Defendants.

OPINION AND ORDER David Cotto, a prisoner without a lawyer, filed an amended complaint under 42 U.S.C. § 1983. (ECF 11.) The court determined that his original complaint did not state a plausible constitutional claim, but he was granted an opportunity to file an amended complaint before the case was dismissed under 28 U.S.C. § 1915A. (ECF 5.) He responded with the present pleading. Under 28 U.S.C. § 1915A, the court must screen the amended complaint and dismiss it if it is frivolous or malicious, fails to state a claim upon which relief may be granted, or seeks monetary relief against a defendant who is immune from such relief. To survive dismissal, a complaint must contain sufficient factual matter to state a claim that is “plausible on its face.” Bell Atlantic Corp. v. Twombly, 550 U.S. 544, 570 (2007). “A claim has facial plausibility when the plaintiff pleads factual content that allows the court to draw the reasonable inference that the defendant is liable for the misconduct alleged.” Ashcroft v. Iqbal, 556 U.S. 662, 678 (2009). Because Cotto is proceeding without counsel, the court must give his allegations liberal construction. Erickson v. Pardus, 551 U.S. 89, 94 (2007).

Cotto is currently an inmate at Pendleton Correctional Facility (“Pendleton”). In May 2024, he was transferred from Miami Correctional Facility (“Miami”) to long-term segregation at the Westville Control Unit (“WCU”) based on a recommendation by the internal affairs department at Miami. He claims he was not given a reason for the transfer. He wrote numerous letters and filed multiple classification appeals but he remained at WCU for approximately eight months before being transferred to

Pendleton. The Fourteenth Amendment Due Process Clause does not create a liberty interest in remaining in the prison’s general population. See Wilkinson v. Austin, 545 U.S. 209, 222 (2005); Sandin v. Conner, 515 U.S. 472, 484 (1995). Instead, “an inmate’s liberty interest in avoiding segregation is limited.” Hardaway v. Meyerhoff, 734 F.3d 740, 743 (7th

Cir. 2013). To trigger a liberty interest, an inmate must be subjected to restrictive conditions that present a “significant and atypical hardship” in relation to the ordinary incidents of prison life. Sandin, 515 U.S. at 484-85. There is no firm rule as to the amount of time that must be spent in segregation to trigger a liberty interest, and instead courts must “look to both the duration of the segregation and the conditions endured.” Lisle v.

Welborn, 933 F.3d 705, 721 (7th Cir. 2019). Cotto describes restrictive conditions at WCU he endured for eight months. This includes being alone in his cell “24/7,” and being unable to socialize with other inmates, attend church, participate in any programs, or order commissary items. Whenever he left his cell, he had to wear a “dog leash” around his neck and shackles on his hands and feet. The court finds that he has plausibly alleged restrictive conditions

that triggered a liberty interest. The demands of due process are not onerous in this context, and inmates are only entitled to “some informal, nonadverserial” process in connection with their detention in long-term segregation. Westefer v. Neal, 682 F.3d 679, 684-85 (7th Cir. 2012). Informal due process requires “some notice” of the reason for the inmate’s placement in long-term segregation and an opportunity to present his views. Id. The inmate is also

entitled to periodic reviews of his placement. Id. The frequency of such review is “committed to the administrative discretion of prison officials.” Id. at 685. Review procedures “need only be sufficiently frequent that administrative segregation does not become a pretext for indefinite confinement.” Id. at 686 (citation omitted). In short, “the requirements of informal due process leave substantial discretion and flexibility in the

hands of the prison administrators.” Id. at 685. Cotto appears to believe he should have been given a full hearing to decide whether his transfer was appropriate, similar to a prison disciplinary proceeding. However, that was not a right he was entitled to under applicable law. See Westefer, 682 F.3d at 684-85. It is also evident from his filings that he was provided a reason for his

placement. Documents reflect that the decision to transfer him to WCU was based on his commission of seven disciplinary offenses during his first year at the Indiana Department of Correction (“IDOC”), including an incident where he was found to be in an unauthorized area of the prison.1 (ECF 1-1 at 1.) Because of his conduct, officials concluded that close observation was needed. (Id.) It can also be discerned that Cotto

was given an opportunity to voice his views on the matter through classification appeals and other filings. Two IDOC officials responded to his classification appeals and letters explaining that his views were considered, but it was determined that his placement was appropriate. (ECF 11 at 5; ECF 1-1 at 10-11.) He also received reviews of his placement on a monthly basis while at WCU. (See ECF 11 at 6-7; ECF 1-1 at 2-13.) That is not the type of infrequency that would violate

due process. Compare Felton v. Brown, 129 F.4th 999, 1009 (7th Cir. 2025) (17-month gap between reviews of inmate’s placement would be unconstitutional). Cotto believes the review process was perfunctory, but the reports of these reviews show he was told the reason for his continued detention: his conduct history and the need for close observation. (See ECF 1-1 at 2-13.) He may disagree with that reasoning, but his

disagreement does not provide a basis for a due process claim. See Meachum v. Fano, 427 U.S. 215, 224 (1976); Antonelli v. Sheahan, 81 F.3d 1422, 1431 (7th Cir. 1996). He also claims that the review procedures did not comply with prison policies, but violations of prison policy are not actionable under 42 U.S.C. § 1983. Scott v. Edinburg, 346 F.3d 752, 760 (7th Cir. 2003) (“42 U.S.C. § 1983 protects plaintiffs from constitutional violations,

not violations of state laws or . . . departmental regulations”). The court cannot

1 Cotto submitted these documents with his original complaint but omitted them from the amended complaint.

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