Diederich v. Washington

CourtDistrict Court, E.D. Michigan
DecidedFebruary 24, 2025
Docket4:19-cv-12799
StatusUnknown

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

Bluebook
Diederich v. Washington, (E.D. Mich. 2025).

Opinion

UNITED STATES DISTRICT COURT EASTERN DISTRICT OF MICHIGAN SOUTHERN DIVISION CHAD DIEDERICH,

Plaintiff, Case No. 19-cv-12799 v. Hon. Matthew F. Leitman

HEIDI WASHINGTON, et al.,

Defendants. __________________________________________________________________/ ORDER GRANTING IN PART AND DENYING IN PART DEFENDANTS’ MOTION FOR SUMMARY JUDGMENT (ECF No. 76) Plaintiff Chad Diederich was formerly an inmate in the custody of the Michigan Department of Corrections (the “MDOC”). Diederich, who was indigent for much of the relevant time period underlying his claims, brought this action pro se under 42 U.S.C. § 1983 against several employees and officials employed by the MDOC. (See Compl., ECF No. 1.) The following claims by Diederich remain alive at this point: that some or all of the remaining Defendants (1) refused to provide him paper and envelopes that he needed to file legal claims and/or motions in various courts (the “Access to Courts Claim”); (2) retaliated against him for filing grievances and lawsuits by transferring him to another prison (the “Retaliation Claim”); and (3) refused to provide him with basic hygiene products (the “Hygiene Claim”). The Defendants have now filed a motion for summary judgment on the remaining claims. (See Mot., ECF No. 76.) Their motion does not raise the defense

of qualified immunity. Diederich, who is now represented by counsel,1 has filed a response to the motion. (See Resp., ECF No. 77.) The Court concludes that it may resolve Defendants’ motion without oral

argument. See E.D. Mich. Local Rule 7.1(f)(2). For the reasons explained below, the motion is GRANTED IN PART and DENIED IN PART. I The Defendants seek summary judgment under Rule 56 of the Federal Rules

of Civil Procedure. Under that rule, a movant is entitled to summary judgment when it “shows that there is no genuine dispute as to any material fact.” SEC v. Sierra Brokerage Servs., Inc., 712 F.3d 321, 326-27 (6th Cir. 2013) (quoting Fed. R. Civ.

P. 56). When reviewing the record, “the court must view the evidence in the light most favorable to the non-moving party and draw all reasonable inferences in its favor.” Id. But “the mere existence of a scintilla of evidence in support of the [non- moving party’s] position will be insufficient; there must be evidence on which the

jury could reasonably find for [that party].” Anderson v. Liberty Lobby, Inc., 477

1 After the case had been pending for a period of time, Attorney Magy E. Shenouda accepted an appointment to represent Diederich on a pro bono basis. She has done an outstanding job on Diederich’s behalf, and the Court greatly appreciates her service. Likewise, Assistant Attorney General O.G. Reasons has done a terrific job representing the Defendants in this action. U.S. 242, 252 (1986). Summary judgment is not appropriate when “the evidence presents a sufficient disagreement to require submission to a jury.” Id. at 251–52.

II The Court begins with Diederich’s Access to Courts Claim. Diederich originally alleged in this claim that some of the Defendants impeded him from

pursuing several court actions. (See Compl., ECF No. 1, PageID.13.) He now contends only that Defendant Nicholas White, a Prison Counselor at the Central Michigan Correctional Facility, hindered his ability to participate in a single proceeding: a habeas corpus action related to criminal charges pending against

Diederich in an Iowa state court. (See Resp., ECF No. 77, PageID.648-651.2) The Court therefore confines its analysis of the Access to Courts Claim to the Iowa habeas proceedings.

A It is well-established that prisoners have a constitutional right of access to the courts. See Bounds v. Smith, 430 U.S. 817, 821 (1977). A claim for denial of

2 The Defendants moved for summary judgment on the entirety of the Access to Courts Claim as originally pleaded, and in Diederich’s response to the motion, he defended only the portion of the claim related to the Iowa habeas proceedings. (See Resp., ECF No. 77, PageID.648-651.) Diederich “is [therefore] deemed to have abandoned” the other portions of the Access to Courts Claim because he “failed to address [those aspects of the claim] in response to [Defendants’] motion for summary judgment.” Brown v. VHS of Michigan, Inc., 545 Fed. App’x 368, 372 (6th Cir. 2013). access to the courts may be “forward-looking” or “backward-looking.” Flagg v. City of Detroit, 715 F.3d 165, 173 (6th Cir. 2013). A forward-looking claim seeks to

“eliminate the condition” blocking the prisoner’s access to the courts. Id. In a backward-looking claim, the prisoner asserts that due to the actions of the defendant, he is “unable to ever obtain an adequate remedy on the underlying claim” that he

wished to pursue in court. Id. Diederich’s remaining Access to Courts Claim looks backwards. To establish his backwards-looking claim, Diederich must show: “(1) a non- frivolous underlying claim, (2) obstructive actions by state actors, (3) substantial

prejudice to the underlying claim that cannot be remedied by the state court, and (4) a request for relief which the plaintiff would have sought on the underlying claim and is now otherwise unattainable.” Id. at 174 (internal citations omitted) (cleaned

up); see also Nguyen v. Floyd, 618 F.Supp.3d 629, 633 (E.D. Mich. 2022). Diederich need not show that the underlying claim “would have been successful; instead, deprivation of an ‘arguable (though not yet established) claim’ is sufficient.” Brown v. Matauszak, 415 F. App’x 608, 612 (6th Cir. 2011) (quoting Lewis v. Casey, 518

U.S. 343, 351 (1996)). Finally, Diederich must show that he suffered “actual injury” as a result of the denial of access. Lewis, 518 U.S. at 349. B Diederich alleges that White denied him access to “proper paper and

envelopes needed to draft and mail filings related to his . . . habeas corpus action,” and as a result, he was unable to timely pursue a writ of habeas corpus in the State of Iowa. (Compl., ECF No. 1, PageID.12.) Diederich’s allegations related to the

Iowa habeas proceedings are difficult to follow. He appears to suggest that had White not interfered with his (Diederich’s) ability to participate in the Iowa habeas proceedings, he could have been transferred from MDOC custody to the custody of the Iowa state court, pleaded guilty to charges pending against him in Iowa, and then

been allowed to serve his Iowa and Michigan sentences concurrently. (See Resp., ECF No. 76, PageID.650-651.) Diederich’s own testimony shows that he lacks sufficient evidence that White

caused him to lose out on any remedy or relief that may have been available to him in the Iowa proceedings: Q: [Y]ou say your ability to pursue a writ of habeas corpus in the state of Iowa. Can you tell me able that claim?

A: Yeah, I had pending charges out of Iowa I was trying to get taken care of, but I couldn’t file a writ of habe[as corpus] with them.

Q: And what do you mean by that? You had pending charges, what were you going to file?

A: A writ of habeas corpus with them. Q: Saying what?

A: To answer the charges they were bringing forth.

Q: Oh, you were going to ask to be transferred to Iowa to – for those charges?

A: Yes.

Q: So what did you lose out on?

A: The ability to pursue those in a timely manner.

Q: So what’s going on with those charges now?

A: They’re still pending.

Q: But you’ve been released from prison, right?

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