Hampton v. Washington

CourtDistrict Court, E.D. Michigan
DecidedFebruary 13, 2025
Docket2:24-cv-10769
StatusUnknown

This text of Hampton v. Washington (Hampton 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
Hampton v. Washington, (E.D. Mich. 2025).

Opinion

UNITED STATES DISTRICT COURT EASTERN DISTRICT OF MICHIGAN SOUTHERN DIVISION

CURTIS L. HAMPTON,

PLAINTIFF, CASE NUMBER: 24-CV-10769 HON. JONATHAN J.C. GREY V.

HEIDI WASHINGTON, ET AL.,

RESPONDENTS. /

OPINION AND ORDER (1) GRANTING PLAINTIFF’S MOTION TO AMEND (ECF NO. 13), (2) DENYING MOTIONS FOR APPOINTMENT OF COUNSEL (ECF NOS. 9, 12), AND (3) PARTIALLY DISMISSING CASE

Before the Court is Plaintiff Curtis L. Hampton’s complaint filed pursuant to 42 U.S.C. § 1983. Hampton, proceeding pro se, is incarcerated at the Saginaw Correctional Facility in Freeland, Michigan. For the reasons discussed, the Court dismisses defendants Washington, Douglas, Anderson, Flaugher, Kusey, and Karnes. The Court also dismisses Hampton’s claims asserted under the Fifth, Eighth, and Fourteenth Amendments, the Federal Tort Claims Act, and various federal criminal statutes. The Court declines to exercise supplemental jurisdiction over Hampton’s state-law claims against the dismissed defendants. I. STANDARD OF REVIEW

Hampton is proceeding without prepayment of the fees and costs in this action. Under the Prison Litigation Reform Act of 1996 (“PLRA”), the Court must screen the complaint before service and dismiss the

complaint, or any portion of the complaint, if it determines the action is frivolous or malicious, fails to state a claim upon which relief can be granted, or seeks monetary relief against a defendant who is immune

from such relief. See 42 U.S.C. § 1997e(c); 28 U.S.C. § 1915(e)(2)(B). To state a claim under 42 U.S.C. § 1983, a civil rights plaintiff must plausibly allege: (1) the violation of a right secured by the Constitution

or another law of the United States, and (2) by a person acting under color of state law. Dominguez v. Corr. Med. Servs., 555 F.3d 543, 549 (6th Cir. 2009). A complaint “does not need detailed factual allegations,” but

the “[f]actual allegations must be enough to raise a right to relief above the speculative level on the assumption that all the allegations in the complaint are true (even if doubtful in fact).” Bell Atlantic Corp. v.

Twombly, 550 U.S. 544, 555 (2007) (footnote and citations omitted). In other words, “a complaint must contain sufficient factual matter, accepted as true, ‘to state a claim to relief that is plausible on its face.’” Ashcroft v. Iqbal, 556 U.S. 662, 678 (2009) (quoting Twombly, 550 U.S. at

570). “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.” Id. (citing Twombly, 550

U.S. at 556). II. PLAINTIFF’S MOTIONS On May 30, 2024, Hampton filed a motion for leave to file an

amended complaint (ECF No. 13) and an amended complaint (ECF No. 14). Federal Rule of Civil Procedure 15(a)(1) allows a party to amend its pleading once as a matter of course. Because Hampton previously filed

an amended complaint (ECF No. 11), he may only amend his complaint by the Court’s leave, which should be freely given when justice so requires. Fed. R. Civ. P. 15(a)(2).

Under Rule 15(a)(2), a motion for leave to amend should only be denied if “there is ‘undue delay, bad faith or dilatory motive on the part of the movant, repeated failure to cure deficiencies by amendments

previously allowed, undue prejudice to the opposing party by virtue of allowance of the amendment, futility of amendment, etc.’” Brown v. Chapman, 814 F.3d 436, 442-443 (6th Cir. 2016) (quoting Foman v. Davis, 371 U.S. 178, 182 (1962)). Hampton’s motion to amend does not

appear to be made in bad faith or to be an attempt to delay the proceedings, nor will it prejudice the opposing party. The Court GRANTS the motion.

When a plaintiff files an amended complaint, the new complaint supersedes all previous complaints and controls the case from that point forward. Parry v. Mohawk Motors of Michigan, Inc., 236 F.3d 299, 306

(6th Cir. 2000) (citing In re Atlas Van Lines, Inc., 209 F.3d 1064, 1067 (8th Cir. 2000)). Hampton also has filed two motions for appointment of counsel.

(ECF Nos. 9, 12.) Appointment of counsel in a civil case is not a constitutional right.” Lavado v. Keohane, 992 F.2d 601, 605 (6th Cir. 1993); Bennett v. Smith, 110 F. App’x 633, 635 (6th Cir. 2004) (“[T]here

is no right to counsel in prisoner civil rights cases.”). Under 28 U.S.C. § 1915(e), “[t]he court may request an attorney to represent any person unable to afford counsel.” § 1915(e)(1) (emphasis added). It is a matter

“within the discretion of the court,” Childs v. Pellegrin, 822 F.2d 1382, 1384 (6th Cir. 1987) (quotation omitted), and “is a privilege that is justified only by exceptional circumstances.” Lavado, 992 F.2d at 606 (quotation omitted). This case does not present exceptional

circumstances warranting appointment of counsel. The motions to appoint counsel are DENIED. III. COMPLAINT

Hampton alleges that, during his incarceration at the Saginaw Correctional Facility, he ordered five books1 from the Edward R. Hamilton Bookseller for a total cost of $ 220.21. Defendants M.

Beauchamp and L. Cummings, mailroom staff, rejected three of the five books because they contained content that was impermissible under MDOC Policy Directive 05.03.118, including images of bondage and sex

acts. On March 28, 2023, Hampton requested an administrative hearing on the rejection by mailroom staff. An administrative hearing was held on August 4, 2023. Defendant

Anderson presided over the hearing and held that the books were properly rejected. Anderson denied Hampton’s requests to review the rejected books prior to and during the hearing. Anderson did not provide

a copy of the hearing report in violation Michigan Department of

1 The five books are: Peep Show/Uncensored Beautifully Sexy, Dirty Girls Having Fun, Kinky Taboo Girls, Super Nylon Parade, and Tattooed Beauties. Corrections (MDOC) policy directive 05.03.118. On April 19, 2023,

corrections officer M. Guerin gave Hampton a copy of the hearing report. Hampton noticed that only one of the rejected books, More Dirty Girls Having Fun, was specifically addressed in the report. Guerin contacted

the mailroom staff and learned that one of the three rejected books, Peep Show/Uncensored Beautifully Sexy, was not in their possession. Guerin suggested that Hampton submit a property claims form for the missing

book. Guerin responded to Hampton’s Step I grievance concerning Anderson’s failure to comply with MDOC policy for the administrative hearing. Guerin directed a rehearing because the hearings report did not

adequately respond to the issues. On May 24, 2023, Anderson attempted to conduct a rehearing, but it was discovered that Hampton’s books had been destroyed by mailroom

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