Cox v. Myers

CourtDistrict Court, D. Nebraska
DecidedMay 13, 2025
Docket8:23-cv-00202
StatusUnknown

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

Bluebook
Cox v. Myers, (D. Neb. 2025).

Opinion

IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF NEBRASKA

TRAVIS COX,

Plaintiff, 8:23-CV-202

vs. MEMORANDUM AND ORDER

BOARD OF PAROLE, et al.,

Defendants.

The plaintiff, Travis Cox, is a prisoner proceeding in forma pauperis. See filing 26. He is suing a number of governmental entities, and officers and employees of those entities. See filing 40. The Court is required to review prisoner complaints seeking relief against such parties to determine whether summary dismissal is appropriate. See 28 U.S.C. §§ 1915(e), 1915A. The Court must dismiss a complaint or any portion of it that states a frivolous or malicious claim, that fails to state a claim upon which relief may be granted, or that seeks monetary relief from a defendant who is immune from such relief. §§ 1915(e)(2)(B), 1915A(b). I. SUMMARY OF COMPLAINT The plaintiff seeks declaratory, injunctive, and compensatory relief for alleged violations of his statutory and civil rights pursuant to 42 U.S.C. § 1983. He asserts the Nebraska Board of Parole, its officers, and several of its employees violated his Fourth Amendment rights when his parole was revoked pursuant to an inaccurate warrant. See filing 40 at 5. He also asserts that the Douglas County Department of Corrections and its director, Mike Myers, have violated his Eighth Amendment rights by ignoring his medical conditions and subjecting him to inhumane prison conditions. He seeks $1 million "against each defendant, jointly as well as severally," and requests an additional $20,000 in damages from each defendant "to be placed into a[n] inmate welfare fund" to address the alleged problems at the correctional facility. Filing 40 at 10.1 According to the plaintiff, his parole was wrongfully revoked after he was accused of absconding from a treatment center. Filing 40 at 5. The plaintiff asserts he did not abscond and he was never in treatment. He asserts that in January 2023, he was sanctioned for failing a urinalysis, and a few weeks later, his parole officer, defendant Danielle Sanders, "issued warrant information" to the Board of Parole. Filing 40 at 7. The plaintiff was then arrested. At the plaintiff's preliminary and revocation hearings, he requested counsel, but his request was denied. Filing 40 at 7. The plaintiff also alleges, while incarcerated with the Douglas County Department of Corrections, he has been refused medical treatment, refused access to medication, and "housed in several units infested with gnats, flies, mice, and rats, all feeding off of raw sewage." Filing 49 at 6. The plaintiff asserts he has not been able to access medical care for Hepatitis C and for several seizures he has had while incarcerated. Filing 40 at 8. He also alleges that "some if not all of the toilets" in the correctional facility "leak raw sewage in the floor when they are flushed." Filing 40 at 8. II. DISCUSSION Improper Joinder The plaintiff's claims involve two separate and distinct situations: First, his alleged wrongful incarceration, and second, the conditions of his confinement.

1 The plaintiff has not alleged any facts relating to several defendants: the State of Nebraska, the Nebraska Department of Correctional Services, and Well Path. The plaintiff has failed to state a claim as to these defendants, and they will be dismissed. 2 As pleaded, the claims alleged and the defendants named in the amended complaint lack the factual or temporal continuity required to allow him to proceed against all of the named defendants in the same action.2 Federal Rule of Civil Procedure 20(a)(2) imposes two specific conditions to join defendants in one action: (1) a right to relief is asserted against them jointly or severally relating to, or arising out of, the same transaction or occurrence, and (2) that any question of law or fact common to all defendants will arise in the action. The word "transaction" in Rule 20 is "a word of flexible meaning," comprehending "a series of many occurrences, depending not so much upon the immediateness of their connection as upon their logical relationship." Patrick Collins, Inc. v. John Does 1-21, 282 F.R.D. 161, 167 (E.D. Mich. 2012), report and recommendation adopted, 286 F.R.D. 319 (E.D. Mich. 2012) (quoting Mosley v. General Motors Corp., 497 F.2d 1330, 1333 (8th Cir. 1974) (internal quotations omitted) (citing Moore v. New York Cotton Exchange, 270 U.S. 593 (1926)). Rule 20 permits any reasonably related claims for relief against different parties to be tried in a single proceeding. See Mosley, 497 F.2d at 1333. Ultimately, while joinder of claims, parties, and remedies are encouraged under the Federal Rules of Civil Procedure, permissive joinder is not applicable in all cases. Id. Because the same rules apply to prisoners as to free persons, if a complaint filed by a free person would be rejected under Rule 20(a)(2), so must it be when filed by a prisoner. See George v. Smith, 507 F.3d 605, 607 (7th Cir. 2007). However, in the prison context, application of Rule 20(a)(2) must also be considered alongside of the Prison Litigation Reform Act (PLRA), which "limits to 3 the number of frivolous suits or appeals that any prisoner may file without

2 While all claims against the same defendant may generally be raised in the same case, the claims against different defendants must meet the transaction or occurrence test. As pleaded, there is no apparent connection between many of the defendants. 3 prepayment of the required fees." Perry, 2023 WL 2781585, at *2 (quoting Smith, 507 F.3d at 606) (internal quotations omitted). Courts have held that permitting improper joinder in a prisoner civil rights action undermines the purpose of PLRA’s three strikes provision, which was enacted to reduce the large number of frivolous prisoner lawsuits that were being filed in the federal courts. Id. (citing Riley v. Kurtz, 361 F.3d 906, 917 (6th Cir. 2004); Brown v. Blaine, 185 F. App'x 166, 168–69 (3d Cir. 2006). Allowing a prisoner-plaintiff to improperly join claims and defendants in a single action not only violates Rule 20(a) but would also permit him to "circumvent the PLRA’s filing fee provisions and allow him to avoid having to incur a 'strike' for purposes of [ ] § 1915(g), should any of his claims turn out to be frivolous." Green v. Callahan, No. 2:14-cv-11453, 2014 WL 1652335, at *3 (E.D. Mich. Apr. 23, 2014). Courts are thus obligated to reject mis-joined claims or parties. See Owens v. Hinsley, 635 F.3d 950, 952 (7th Cir. 2011). In this case, there are two distinct harms alleged by the plaintiff: the wrongful revocation of his parole, and the unconstitutional conditions of his confinement. These harms have no facts or legal theories in common. While arguably the Board of Parole's decision to revoke the plaintiff's parole was the reason he was subject to the allegedly inhumane conditions in prison, the Board of Parole defendants cannot be jointly and severally liable for the independent wrongs alleged of the Douglas County Department of Corrections, nor is there a common question of law or fact common to all defendants.

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Cox v. Myers, Counsel Stack Legal Research, https://law.counselstack.com/opinion/cox-v-myers-ned-2025.