Gritts 143652 v. Martinez

CourtDistrict Court, D. Arizona
DecidedOctober 9, 2020
Docket2:16-cv-01233
StatusUnknown

This text of Gritts 143652 v. Martinez (Gritts 143652 v. Martinez) is published on Counsel Stack Legal Research, covering District Court, D. Arizona primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Gritts 143652 v. Martinez, (D. Ariz. 2020).

Opinion

1 WO 2 3 4 5 6 IN THE UNITED STATES DISTRICT COURT 7 FOR THE DISTRICT OF ARIZONA 8 9 Lucas Lee Gritts, No. CV 16-01233-PHX-GMS 10 Plaintiff, 11 v. ORDER 12 Unknown Martinez, et al.,

13 Defendants.

14 15

16 Pending before the Court are Defendants Martinez et al.s’ (“Defendants”) Motion 17 for Summary Judgment (Doc. 148) and Plaintiff Lucas Lee Gritt’s (“Plaintiff”) Cross- 18 Motion for Summary Judgment. (Doc. 153.) For the following reasons, Defendants’ 19 Motion is granted, and Plaintiff’s Motion is denied.1 20 BACKGROUND 21 The facts and procedural history are known to the parties and have been discussed 22 in detail in the Court’s orders addressing prior motions for summary judgment. (Doc. 66; 23 Doc. 75.) Plaintiff’s claim against Defendants arises out of several disciplinary hearings. 24 The parties agree about the core facts surrounding these events. In October 2015, Plaintiff 25 was convicted of conspiring to assault a correctional officer at a disciplinary hearing he 26 27 1 Defendant also seeks summary judgment on Plaintiff’s claim for injunctive relief. 28 The Court already resolved this claim at the parties’ December 2019 Status Conference. (Doc. 150 at 4.) Defendants’ motion is therefore only granted as to the claims that have not already been addressed. 1 was not allowed to attend. As a result of that conviction, he lost 200 early release credits 2 (“ERCs”). In a separate hearing, Plaintiff was also removed from the step-down program, 3 which allows inmates to earn access to lower-security housing, because of his disciplinary 4 conviction. Plaintiff subsequently filed suit, alleging due process violations for denial of 5 his rights to attend and present evidence at the October 2015 hearing. In May 2019 a second 6 disciplinary hearing was held, reconsidering the earlier charge of conspiracy to assault an 7 officer. Plaintiff was again convicted of the charge, but his punishment was modified to 8 deduct only 120 ERCs. Plaintiff was never returned to the step-down program. Plaintiff 9 amended his complaint to include allegations that he was not permitted to present evidence 10 at this hearing as well. He seeks damages for these alleged due process violations and the 11 resulting change of conditions. Plaintiff was released from custody in August 2019. 12 DISCUSSION 13 1. Legal Standard 14 The purpose of summary judgment is “to isolate and dispose of factually 15 unsupported claims.” Celotex Corp. v. Catrett, 477 U.S. 317, 323–24 (1986). Summary 16 judgment is appropriate if the evidence, viewed in the light most favorable to the 17 nonmoving party, shows “that there is no genuine issue as to any material fact and that the 18 movant is entitled to judgment as a matter of law.” Fed. R. Civ. P. 56(c). Only disputes 19 over facts that might affect the outcome of the suit will preclude the entry of summary 20 judgment, and the disputed evidence must be “such that a reasonable jury could return a 21 verdict for the nonmoving party.” Anderson v. Liberty Lobby, Inc., 477 U.S. 242, 248 22 (1986). 23 “[A] party seeking summary judgment always bears the initial responsibility of 24 informing the district court of the basis for its motion and identifying those portions of [the 25 record] which it believes demonstrate the absence of a genuine issue of material fact.” 26 Celotex, 477 U.S. at 323. Parties opposing summary judgment are required to “cit[e] to 27 particular parts of materials in the record” establishing a genuine dispute or “show[ ] that 28 the materials cited do not establish the absence . . . of a genuine dispute.” Fed. R. Civ. P. 1 56(c)(1). A district court has no independent duty “to scour the record in search of a 2 genuine issue of triable fact[.]” Keenan v. Allan, 91 F.3d 1275, 1279 (9th Cir. 1996). 3 “[W]hen simultaneous cross-motions for summary judgment on the same claim are before 4 the court, the court must consider the appropriate evidentiary material identified and 5 submitted in support of both motions, and in opposition to both motions, before ruling on 6 each of them.” Fair Hous. Council of Riverside Cty., Inc. v. Riverside Two, 249 F.3d 1132, 7 1134 (9th Cir. 2001). 8 2. The Favorable Termination Rule 9 The favorable termination rule, articulated in Heck v. Humphrey, states that a 10 prisoner cannot bring a § 1983 suit for damages where a judgment in their favor would 11 necessarily imply the invalidity of the underlying conviction or sentence; if it would, the 12 complaint must be dismissed unless the plaintiff can demonstrate that the conviction or 13 sentence has already been invalidated. 512 U.S. 477, 486–87 (1994). In Edwards v. 14 Balisok, the Supreme Court applied Heck to prison disciplinary proceedings. 520 U.S. 641, 15 643 (1997). The inmate’s principal claims were that he was denied the opportunity to 16 present a defense and that the hearing officer was partial. Id. at 646–47. Heck barred the 17 claim because “a criminal defendant tried by a partial judge is entitled to have his 18 convictions set aside, no matter how strong the evidence against him.” Id. at 647. A 19 judgment in the inmate’s favor would therefore necessarily imply the invalidity of the 20 underlying conviction. Id. Balisok thus “extended the favorable termination rule to prison 21 disciplinary actions that implicated the prisoner’s term of confinement.” Ramirez v. 22 Galaza, 334 F.3d 850, 856 (9th Cir. 2003). Although the prisoner did not seek 23 reinstatement of his good time credits, he could not circumvent application of Heck because 24 the alleged due process defect implied the invalidity of the deprivation of the credits. Id. 25 Ninth Circuit precedent has interpreted Balisok both broadly and narrowly,2 but 26 27 2 Compare Butterfield v. Bail, 120 F.3d 1023, 1025 (9th Cir. 1997) (finding that the plaintiff’s claim that his due process rights were violated because false information was 28 considered when denying his parole necessarily implicated the validity of the denial of parole, despite the fact that the plaintiff sought only damages), and Gotcher v. Wood, 122 1 using either analysis, Heck’s application is driven by the nature of the due process violation 2 an inmate claims. See Huftile v. Miccio-Fonseca, 410 F.3d 1136, 1140 (9th Cir. 2005) (“In 3 determining whether a judgment in favor of a section 1983 plaintiff necessarily implies the 4 invalidity of his underlying conviction, we take into account the particular facts of the 5 criminal trial or other proceeding leading to the allegedly improper detention.”). The 6 Court’s conclusion in Balisok, for example, was predicated on the specific due process 7 violation of a partial arbiter, which would necessarily invalidate the underlying conviction. 8 Balisok, 520 U.S. at 647. It does not follow, as Defendants claim, that all procedural due 9 process errors necessarily call into question the validity of a conviction from a prison 10 disciplinary board. The nature of Plaintiff’s specific claim, however, does imply the 11 invalidity of his underlying conviction.

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Related

Anderson v. Liberty Lobby, Inc.
477 U.S. 242 (Supreme Court, 1986)
Heck v. Humphrey
512 U.S. 477 (Supreme Court, 1994)
Edwards v. Balisok
520 U.S. 641 (Supreme Court, 1997)
Villafane-Neriz v. Federal Deposit Insurance
20 F.3d 35 (First Circuit, 1994)
Michael Huftile v. L C Miccio-Fonseca
410 F.3d 1136 (Ninth Circuit, 2005)
Keenan v. Allan
91 F.3d 1275 (Ninth Circuit, 1996)
Butterfield v. Bail
120 F.3d 1023 (Ninth Circuit, 1997)
Hiltunen v. Bayer
6 F. App'x 629 (Ninth Circuit, 2001)
Ramirez v. Galaza
334 F.3d 850 (Ninth Circuit, 2003)
Smith v. Americredit Financial Services, Inc.
461 F. App'x 585 (Ninth Circuit, 2011)
Cox v. Clark
321 F. App'x 673 (Ninth Circuit, 2009)

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