Hairston v. Wilson

CourtDistrict Court, E.D. Virginia
DecidedJune 24, 2021
Docket1:19-cv-00862
StatusUnknown

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

Bluebook
Hairston v. Wilson, (E.D. Va. 2021).

Opinion

IN THE UNITED STATES DISTRICT COURT FOR THE EASTERN DISTRICT OF VIRGINIA Alexandria Division Jerry Lee Hairston, ) Plaintiff, ) 1:19ev862 (AJT/MSN) Jason Wilson, et al., Defendants. ) MEMORANDUM OPINION Jerry Lee Hairston, a Virginia inmate proceeding pro se, has filed a civil-rights action under 42 U.S.C. § 1983, claiming that his due process rights were violated while he was detained at the Virginia Center for Behavioral Rehabilitation (VCBR) under a civil committed order. He seeks compensatory and punitive damages, as well as preliminary and permanent injunctive relief that would modify policies at VCBR. In two motions, defendants Jason Wilson, Anita Schlank, Royace Baugh, Sarah Webster, Omar Higgins, and Brittany Pride move to dismiss the claims against them for lack of jurisdiction, see Fed. R. Civ. P. 12(b)(1), and failure to state a claim for relief, see id. 12(b)(6). [Dkt. Nos. 29, 42]. Hairston has received the notice required by Local Civil Rule 7(K) and Roseboro v. Garrison, 528 F.2d 309 (4th Cir. 1975), [Dkt. No. 29], and opposes defendants’ motions, [Dkt. No. 33]. Because the claims for injunctive relief are moot and the complaint does not plausibly allege that Hairston was denied a liberty interest without due process, the motions to dismiss will be granted. I. The Complaint When Hairston filed the complaint, he was civilly detained at VCBR after a state court found that he was a sexually violent predator under the Civil Commitment of Sexually Violent Predators Act (SVPA). See Va. Code § 37.2-900 to 37.2-921; [Def. Mot. to Dismiss, Ex. 1 & 2].

The events underlying the complaint took place there. Below, the Court recounts the complaint’s factual allegations, which the Court accepts as true for the purpose of ruling on the motion to dismiss. See Erickson v. Pardus, 551 U.S. 89, 94 (2007). The Court also may consider the attachments to the complaint and public records without having to convert the motion to dismiss into a motion for summary judgment. See Walker v. Kelly, 589 F.3d 127, 139 (4th Cir. 2009). In this lawsuit Hairston principally takes issue with a report—specifically, an observation note written on October 11, 2018—that caused a setback to his treatment progression at VCBR. An observation note is part of a detainee’s treatment record and documents behavior, including behavior related to phase goals, behavior related to violations of rules and privileges, and refusals of medical appointments, medication, and meals. [Dkt. No. 1, Compl. Ex. 1]. VCBR has a three-phase treatment program. [Id.]. On September 25, 2018—weeks before the observation note was written—Hairston was placed on Phase II probation. [Dkt. No. 12, Amended Compl. Ex. 13]. Then, on October 19, Hairston was demoted from Phase II to Phase I “due to engaging in a sexual acting out behavior” and for withdrawing his consent for treatment. [Id. Ex. 14]. That same day, Hairston’s therapist, Higgins, discussed the observation note that had been written by Pride a few days earlier. [Id. § 6-7]. In the observation note, Pride reported that during the evening of October 11, when “I checked room 14 seen [sic] resident Hairston beating his penis.” [Id. Ex. 3]. The note was classified as “other sexual behavior.” [Id.]. Hairston asserts that “[t]his was a major infraction that required me to be placed on the Behavioral Unit, and be placed on Privilege Level D, Red Card.” [Id. ] 7]. Hairston denied that he engaged in the behavior reported in the observation note. [Id. § 8]. Higgins informed Hairston that he would have to seek an amendment to challenge the note’s content. [Id. | 9}.

Hairston submitted to Baugh, the director of Residential Services, an amendment requesting that the observation note be removed from his record because he did not engage in the reported behavior. [Id.]. Baugh did not remove the note; instead, he recategorized it from “other sexual behavior” to “other” because “[u]Jpon review of the activities that lead to this documentation it has been determined that there are discrepancies which were not accurately documented.” [Dkt. No. 1, Compl. Ex. 3]. After the note was recategorized, Higgins told Pride to rewrite the observation note to reflect that ‘Mr. Hairston was observed with his hands in his pants and movement in his groin area.” [Dkt. No. 12, Amended Compl. 10; Dkt. No. 1, Compl. Ex. 6, at p. 4]. When confronted with the rewritten observation note, Hairston “consistently noted that he was not masturbating or exhibiting any other sexual act” and asserted, instead, “that there was a possibility while resting in bed... he could have been scratching his leg because of his eczema.” [Dkt. No. 1, Compl. Ex. 6, at p. 5]. Higgins’s treatment team ultimately “concluded that the narrative of the observation note depicts inappropriate sexual behavior, which is a violation of Phase I goals.” [Id.]. The complaint does not clearly state what claims Hairston seeks to bring based on these allegations. Liberally construing the complaint, see Erickson, 551 U.S. at 94, the Court gleans that Hairston seeks to bring the following three due process claims based on his phase demotion and the role that the observation note played in it: (1) A phase demotion amounts to punishment in contravention of his substantive due process rights; (2) he has liberty interest in advancing through VCBR’s treatment for civilly committed sexual violent predators and the phase demotion, which was based on an observation note and imposed without a hearing, interfered with that interest; and (3) there was insufficient evidence to support the phase demotion.

Il. Standard of Review Defendants move to dismiss the complaint under Rules 12(b)(1) and 12(b)(6). “A 12(b)(1) motion addresses whether [plaintiff] has a right to be in the district court at all and whether the court has the power to hear and dispose of his claim, and a 12(b)(6) motion addresses whether [plaintiff] has stated a cognizable claim, a challenge to the sufficiency of the complaint.” Holloway v. Pagan River Dockside Seafood, Inc., 669 F.3d 448, 452 (4th Cir. 2012).

Il. Analysis A) Rule 12(b)(1) In a supplemental motion to dismiss, defendants argue that Hairston’s claims for declaratory and injunctive relief are moot because he has been released from VCBR, and, thus, he is no longer subject to the observation note policies he seeks to change through this lawsuit. Defendants are correct. A detainee’s transfer to a “location where he is no longer subject to the challenged policy, practice, or condition moots his claims for injunctive and declaratory relief, even if a claim for money damages survives.” Incumaa v. Ozmint, 507 F.3d 281, 286-87 (4th Cir. 2007). Because Hairston is no longer confined at VCBR, his claims seeking declaratory and injunctive relief related to the observation note policies are now moot and must be dismissed for lack of subject matter jurisdiction.

B) Rule 12(b)(6) i. Constitutional Claims! Defendants argue that Hairston has failed to state a claim for relief under the due process clause of the Fourteenth Amendment based on his demotion from Phase II to Phase I at VCBR.

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Bluebook (online)
Hairston v. Wilson, Counsel Stack Legal Research, https://law.counselstack.com/opinion/hairston-v-wilson-vaed-2021.