CRAIG v. SEVIER

CourtDistrict Court, S.D. Indiana
DecidedApril 28, 2025
Docket1:24-cv-01329
StatusUnknown

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

Bluebook
CRAIG v. SEVIER, (S.D. Ind. 2025).

Opinion

UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF INDIANA INDIANAPOLIS DIVISION

COREY ALLEN CRAIG, ) ) Plaintiff, ) ) v. ) No. 1:24-cv-01329-JMS-TAB ) MARK SEVIER Warden, New Castle Correctional ) Facility, et al., ) ) Defendants. )

ORDER SCREENING AMENDED COMPLAINT AND DISMISSING ACTION Corey Craig alleges violations of his civil rights while incarcerated at New Castle Correctional Facility. The Court screened Mr. Craig's complaint pursuant to 28 U.S.C. § 1915A, dismissed it for failure to state a plausible claim for relief, and directed him to file an amended complaint. Because Mr. Craig filed this action while incarcerated, the Court must screen the amended complaint pursuant to 28 U.S.C. § 1915A. I. Screening Standard When screening a complaint, the Court must dismiss any portion that is frivolous or malicious, fails to state a claim for relief, or seeks monetary relief against a defendant who is immune from such relief. 28 U.S.C. § 1915A(b). To determine whether the complaint states a claim, the Court applies the same standard as when addressing a motion to dismiss under Federal Rule of Civil Procedure 12(b)(6). See Schillinger v. Kiley, 954 F.3d 990, 993 (7th Cir. 2020). Under that standard, a complaint must include "enough facts to state a claim to relief that is plausible on its face." Bell Atl. 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). The Court construes pro se complaints liberally and holds them to a "less stringent standard than pleadings drafted by lawyers." Cesal v. Moats, 851 F.3d 714, 720 (7th Cir. 2017). II. The Amended Complaint

Mr. Craig seeks damages and injunctive relief from three defendants: Officer Hamrick, the Indiana Department of Correction (IDOC), and Warden Mark Sevier. He bases his claims on the following allegations, which the Court accepts as true at the pleading stage. See Lisby v. Henderson, 74 F.4th 470, 472 (7th Cir. 2023). Mr. Craig alleges that, on June 18, 2024, Officer Hamrick prevented him from attending the "Kairos Prayer and Share" activity, where inmates from various religious backgrounds learn about one another's religions. He alleges that Officer Hamrick also lied in a conduct report, which resulted in him losing earned credit time or being demoted in credit-earning class. III. Discussion of Claims Like the original complaint, the amended complaint fails to state a plausible claim for

relief. Therefore, the action must be dismissed pursuant to § 1915A. Any claim for injunctive relief must be dismissed as moot because Mr. Craig is no longer incarcerated at the facility where the violations he alleges took place. See dkt. 18 (notice of change of address). "[W]hen a prisoner who seeks injunctive relief for a condition specific to a particular prison is transferred out of that prison, the need for relief . . . become[s] moot." Lehn v. Holmes, 364 F.3d 862, 871 (7th Cir. 2004). Any claim for relief from the disciplinary action against him must be pursued in a petition for a writ of habeas corpus, not a lawsuit for injunctive relief or damages. "[W]hen a state prisoner is challenging the very fact or duration of his physical imprisonment, and the relief he seeks is a determination that he is entitled to immediate release or a speedier release from that imprisonment, his sole federal remedy is a writ of habeas corpus." Preiser v. Rodriguez, 411 U.S. 475, 500 (1973). The IDOC web site indicates that Mr. Craig was released on parole in October 2024.1 "To the extent" Mr. Craig "wants to challenge the duration of his parole (a form of custody), a petition for

a writ of habeas corpus is the proper vehicle." Brown v. Brookhart, 530 F. App'x 592, 593 (7th Cir. 2013) (citing Preiser, 411 U.S. at 486 n.6). Any claim for damages based on the disciplinary action is barred by the doctrine of Heck v. Humphrey, 512 U.S. 477 (1994). Under Heck and Edwards v. Balisok, 520 U.S. 641 (1997), a prisoner deprived of good credit time in a disciplinary proceeding cannot bring a suit for damages that would imply the invalidity of the disciplinary conviction and sanctions. Whether the plaintiff asserts that his disciplinary conviction and sanctions are not supported by evidence or that he was denied a procedural protection, he cannot bring a suit for damages or declaratory relief unless "the conviction or sentence has previously been invalidated." Balisok, 520 U.S. at 643, 648. Mr. Craig's complaint indicates that he was deprived of credit time or demoted in credit-earning class and does

not indicate that those sanctions have been invalidated. James v. Pfister, 708 F. App'x 876, 878– 79 (7th Cir. 2017) ("Heck and Edwards define an affirmative defense, . . . and only when the application of an affirmative defense is apparent from the complaint should a district court invoke it at screening under § 1915A."). Any claim for damages based on the theory that Mr. Craig was wrongly prevented from attending a religious activity on one occasion must be dismissed because those allegations do not support a reasonable inference that Mr. Craig's rights were violated. Prisoners' rights to exercise their religious beliefs are protected by the First Amendment and by the Religious Land Use and

1 IDOC, Indiana Incarcerated Database Search, https://offenderlocator.idoc.in.gov/idoc-ofs- 1.0.2/ofs?offnum=156913&search2.x=0&search2.y=0 (last visited Apr. 14, 2025). Institutionalized Persons Act (RLUIPA). Under either provision, a plaintiff must offer facts supporting a reasonable inference that the defendant substantially limited his ability to exercise his sincerely held religious beliefs.2 And, without more, an allegation that a prison official prevented participation in a religious service on one occasion is not sufficient to allege a substantial burden.

See, e.g., Gregory v. Sevier, No. 3:18-cv-633-JD-MGG, 2020 WL 638790, at *3 (N.D. Ind. Feb. 11, 2020) (Defendants who "each prevented Gregory from bringing his bible to the chapel on only a single occasion . . . did not impose a substantial burden on Gregory's religious beliefs."); Hampton v. Chaplin, No. 1:16-cv-00854-TWP-MPB, 2016 WL 2595187, at *1 (S.D. Ind. May 4, 2016) ("But the inability to participate in a religious service on one occasion is insufficient to establish a constitutional violation."); Powers v. Scott, No. 14-cv-3201, 2014 WL 3907772, at *2 (C.D. Ill. Aug. 11, 2014) ("The fact that she abruptly ended one religious service on one occasion does not rise to the level of a constitutional violation."); Wing v. Braye, No. CIV. 10-510-GPM, 2010 WL 5169558, at *2 (S.D. Ill. Dec.

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Related

Preiser v. Rodriguez
411 U.S. 475 (Supreme Court, 1973)
Turner v. Safley
482 U.S. 78 (Supreme Court, 1987)
Heck v. Humphrey
512 U.S. 477 (Supreme Court, 1994)
Edwards v. Balisok
520 U.S. 641 (Supreme Court, 1997)
Bell Atlantic Corp. v. Twombly
550 U.S. 544 (Supreme Court, 2007)
Ashcroft v. Iqbal
556 U.S. 662 (Supreme Court, 2009)
Donald A. Lehn v. Michael L. Holmes
364 F.3d 862 (Seventh Circuit, 2004)
Kerry Brown v. Deanna Brookhart
530 F. App'x 592 (Seventh Circuit, 2013)
Kirk Horshaw v. Mark Casper
910 F.3d 1027 (Seventh Circuit, 2018)
Daniel Schillinger v. Josh Kiley
954 F.3d 990 (Seventh Circuit, 2020)
Rufus West v. Dylon Radtke
48 F.4th 836 (Seventh Circuit, 2022)
Nuñez v. Indiana Department of Child Services
817 F.3d 1042 (Seventh Circuit, 2016)
Colbert v. City of Chicago
851 F.3d 649 (Seventh Circuit, 2017)
Cesal v. Moats
851 F.3d 714 (Seventh Circuit, 2017)
James v. Pfister
708 F. App'x 876 (Seventh Circuit, 2017)
Ralph Lisby v. Jonathan Henderson
74 F.4th 470 (Seventh Circuit, 2023)

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CRAIG v. SEVIER, Counsel Stack Legal Research, https://law.counselstack.com/opinion/craig-v-sevier-insd-2025.