Hart v. Georgia Department of Corrections

CourtDistrict Court, N.D. Georgia
DecidedJune 16, 2025
Docket1:24-cv-04814
StatusUnknown

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

Bluebook
Hart v. Georgia Department of Corrections, (N.D. Ga. 2025).

Opinion

IN THE UNITED STATES DISTRICT COURT FOR THE NORTHERN DISTRICT OF GEORGIA ATLANTA DIVISION

JONATHAN ANDREW HART, Plaintiff, v. Civil Action No. GEORGIA DEPARTMENT OF 1:24-cv-04814-SDG CORRECTIONS, et al., Defendants.

OPINION AND ORDER This case is before the Court on various motions filed by Plaintiff Jonathan Andrew Hart. For the reasons stated below, the Court orders as follows: 1. Hart’s motion for extension of time to file objections [ECF 16] is GRANTED nunc pro tunc; 2. Hart’s motion to set aside dismissal [ECF 18] is DENIED; 3. Hart’s motion for appointment of counsel [ECF 22] is DENIED; 4. Hart’s application to appeal in forma pauperis [ECF 24] is DENIED; and 5. Hart’s motion for relief from prepayment of fees [ECF 25] is DENIED as moot. I. Background On December 16, 2024, United States Magistrate Judge John K. Larkins, III entered a Final Report and Recommendation (R&R) recommending that this action be dismissed pursuant to 28 U.S.C. § 1915A for failure to state a viable claim for relief.1 After the time for objections to the R&R passed, undersigned reviewed the R&R for clear error and, finding none, adopted the R&R as the Order of this

Court and dismissed the complaint.2 However, shortly after the dismissal was docketed, the Clerk received Hart’s motion for an extension of time to file his objections.3 The motion was dated

December 26, 2024, and under the “prison mailbox rule” it is deemed to have been filed prior to the expiration of time for Hart to file his objections.4 Because Hart’s motion establishes good cause for the extension, the Court will grant the requested extension and deem Hart’s objections timely filed. Accordingly, undersigned will

review the objections to determine whether Hart has shown that the December 30, 2024 Order dismissing the complaint should be vacated. Hart, an inmate at the Jenkins Correctional Facility in Millen, Georgia, filed

the instant 42 U.S.C. § 1983 civil rights action against the Georgia Department of Corrections and various prison officials, claiming that in 2013 he was improperly

1 ECF 9. 2 ECF 14. 3 ECF 16. 4 Under the prison mailbox rule “a pro se prisoner’s court filing is deemed filed on the date it is delivered to prison authorities for mailing.” Williams v. McNeil, 557 F.3d 1287, 1290 n.2 (11th Cir. 2009). Courts assume, “[a]bsent evidence to the contrary, . . . that a prisoner delivered a filing to prison authorities on the date that he signed it.” Jeffries v. United States, 748 F.3d 1310, 1314 (11th Cir. 2014). classified as a member of the Aryan Nation gang.5 Hart insists that he is not a member of the gang, that the designation has put him in danger of attack by other

inmates, and that he has repeatedly sought to have the designation changed without success.6 Hart also contends that the false designation violates his equal protection, due process, and Eighth Amendment rights.7 He also raises First

Amendment free exercise claims and a claim of slander based on the designation.8 The R&R distilled Hart’s allegations into four claims under § 1983: (1) equal protection, (2) due process, (3) deliberate indifference, and (4) slander.9 First, the R&R concluded that the complaint did not state an equal protection claim because

Hart had not shown that similarly situated prisoners were treated differently, and, in the absence of a suspect classification, he had not shown that his designation was not rationally related to the legitimate penological objective of prison

security.10 Second, the R&R concluded that Hart’s due process claim failed because he does not have a liberty interest in any particular classification.11 Third, the R&R

5 ECF 1, at 4. 6 Id. at 4–5. 7 Id. at 5. 8 Id. 9 See generally ECF 9. 10 Id. at 5–8. 11 Id. at 9. concluded that Hart had not stated an Eighth Amendment deliberate indifference claim because he had not alleged that he suffered any harm.12 Lastly, the R&R

concluded that Hart’s slander claim is not actionable under § 1983.13 The R&R therefore recommended that Hart’s complaint be dismissed. Undersigned adopted the R&R as the Order of this Court and dismissed this case with

prejudice.14 In addition to his objections, Hart filed a motion to set aside the dismissal on the ground that he did not have sufficient time to file his objections.15 Subsequently, Hart filed a motion for the appointment of counsel, as Jenkins was

then on emergency lockdown, which prevented him from accessing the law library,16 followed by an application to appeal in forma pauperis and a motion for relief from prepayment of appellate filing fees.17

II. Applicable Legal Standard A party challenging a report and recommendation issued by a United States Magistrate Judge must file written objections that specifically identify the portions

12 Id. at 10–11. 13 Id. at 11. 14 ECF 14. 15 ECF 18. 16 ECF 22. 17 ECFs 24, 25. of the proposed findings and recommendations to which an objection is made and must assert a specific basis for the objection. United States v. Schultz, 565 F.3d 1353,

1361 (11th Cir. 2009). The district court must “make a de novo determination of those portions of the report or specified proposed findings or recommendations to which objection is made.” 28 U.S.C. § 636(b)(1); Jeffrey S. ex rel. Ernest S. v. State Bd.

of Educ. of Ga., 896 F.2d 507, 512 (11th Cir. 1990). Absent objection, the district court “may accept, reject, or modify, in whole or in part, the findings or recommendations made by the magistrate judge,” 28 U.S.C. § 636(b)(1), and need only satisfy itself that there is no clear error on the

face of the record. Fed. R. Civ. P. 72(b). The district court has broad discretion in reviewing a magistrate judge’s report and recommendation. In addressing objections, it may consider an argument that was never presented to the magistrate

judge, and it may also decline to consider a party’s argument that was not first presented to the magistrate judge. Williams v. McNeil, 557 F.3d 1287, 1290–92 (11th Cir. 2009). Further, “[f]rivolous, conclusive, or general objections need not be

considered by the district court.” Schultz, 565 F.3d at 1361 (quoting Marsden v. Moore, 847 F.2d 1536, 1548 (11th Cir. 1988)). The Court recognizes that Hart is appearing pro se. Thus, it must construe the complaint leniently and hold it “to less stringent standards than formal

pleadings drafted by lawyers.” Erickson v. Pardus, 551 U.S. 89, 94 (2007) (internal citations omitted) (internal quotation marks omitted); see also Tannenbaum v. United States, 148 F.3d 1262, 1263 (11th Cir. 1998). But even a pro se plaintiff must comply

with the threshold requirements of the Federal Rules of Civil Procedure. Moon v. Newsome, 863 F.2d 835, 837 (11th Cir.

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