HOOTEN v. BROWN

CourtDistrict Court, S.D. Indiana
DecidedSeptember 29, 2025
Docket2:23-cv-00191
StatusUnknown

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

Bluebook
HOOTEN v. BROWN, (S.D. Ind. 2025).

Opinion

UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF INDIANA TERRE HAUTE DIVISION

MICHAEL HOOTEN, ) ) Plaintiff, ) ) v. ) No. 2:23-cv-00191-JPH-DML ) RICHARD BROWN, et al., ) ) Defendants. )

ORDER GRANTING DEFENDANTS' MOTION FOR SUMMARY JUDGMENT

Plaintiff Michael Hooten is an Indiana Department of Correction ("IDOC") inmate housed at Wabash Valley Correctional Facility ("Wabash Valley"). In this action, he alleges that Defendants held him in segregation at Wabash Valley for an extended period without meaningful review, in violation of his Fourteenth Amendment rights. Defendants have moved for summary judgment. Dkt. 56. They advance several arguments as to why they are entitled to summary judgement, including that Mr. Hooten was afforded meaningful, periodic review of his placement in administrative segregation. Id. The undisputed record supports this argument, and no reasonable trier of fact could reach a different conclusion. Therefore, the Court does not reach the Defendants' remaining arguments. For the reasons below, that motion, dkt. [56], is GRANTED. I. Standard of Review A motion for summary judgment asks the Court to find that a trial is unnecessary because there is no genuine dispute as to any material fact and, instead, the movant is entitled to judgment as a matter of law. See Fed. R. Civ. P. 56(a). When reviewing a motion for summary judgment, the Court views the record and draws all reasonable inferences from it in the light most favorable to the nonmoving party. Khungar v. Access Cmty. Health Network, 985 F.3d 565,

572–73 (7th Cir. 2021). It cannot weigh evidence or make credibility determinations on summary judgment because those tasks are left to the fact- finder. Miller v. Gonzalez, 761 F.3d 822, 827 (7th Cir. 2014). A court only has to consider the materials cited by the parties, see Fed. R. Civ. P. 56(c)(3); it need not "scour the record" for evidence that might be relevant. Grant v. Trs. of Ind. Univ., 870 F.3d 562, 573−74 (7th Cir. 2017) (cleaned up). A party seeking summary judgment must inform the district court of the basis for its motion and identify the record evidence it contends demonstrates

the absence of a genuine issue of material fact. Celotex Corp. v. Catrett, 477 U.S. 317, 323 (1986). Whether a party asserts that a fact is undisputed or genuinely disputed, the party must support the asserted fact by citing to particular parts of the record, including depositions, documents, or affidavits. Fed. R. Civ. P. 56(c)(1)(A). Failure to properly support a fact in opposition to a movant's factual assertion can result in the movant's fact being considered undisputed,

and potentially in the grant of summary judgment. Fed. R. Civ. P. 56(e). II. Factual Background Because Defendants have moved for summary judgment under Rule 56(a), the Court views and recites the evidence in the light most favorable to Mr. Hooten and draws all reasonable inferences in his favor. Khungar, 985 F.3d at 572–73. A. The parties1 Mr. Hooten was transferred from Pendleton Correctional Facility to

Wabash Valley on April 25, 2019, after he assaulted a staff member, and was housed in disciplinary segregation ("DRSH") at Wabash Valley for one year. Dkt. 63 at 2. On April 25, 2020, Mr. Hooten's classification changed from disciplinary segregation to administrative segregation. Dkt. 62-1 at 1. On March 9, 2021, he was recommended for release from administrative segregation and transfer to any level four general population facility. Dkt. 62-2 at 17. Defendant Jerry Snyder was the Unit Team Manager at Wabash Valley.

Dkt. 63 at 1. Defendant Jack Hendrix was the Executive Director of Classification for the IDOC. Dkt. 58 at 7. B. Mr. Hooten's placement in administrative segregation and review of that placement

1 In his reply to Defendants' motion for summary judgment, Mr. Hooten relinquished all claims against Defendant Richard Brown, IDOC Executive Director. Dkt. 63 at 4. The Court therefore declines to discuss the claim against him further. On April 7, 2020, Acting Warden Kevin Gilmore recommended to IDOC Executive Director Michael Osburn that Mr. Hooten be assigned to Department Wide Administrative Restrictive Status Housing ("ARSH") based on his serious conduct history, recent serious conduct, and recent staff assault with injury.

Dkt. 62-2 at 11. On April 17, 2020, Mr. Hooten's transfer to administrative segregation was approved. Id. at 27. Mr. Hooten submitted a classification appeal in April 2020 upon the determination that he would be moved to administrative segregation and requested that he be kept under review for only a short while before being released to general population as soon as possible. Dkt. 62-2 at 59. Executive Director Jack Hendrix denied this appeal on May 11, 2020, explaining that Mr. Hooten's placement was appropriate based on guilty findings in the two Class

B conduct reports in January 2020, as well as an "unwillingness to follow the rules and regulations." Id. at 37. For the first eight weeks that Mr. Hooten was in administrative segregation, he received reviews every seven days from May 1 to June 19, 2020. Dkt. 57-1 at 24–25, 42, 49–53. These reviews largely remained the same with only the number pertaining to the day of review changing (7-day; 14-day; 21- day, etc.). Each dictated that Mr. Hooten was to remain in administrative

segregation based on the following rationales: threat to facility security, additional observation needed, overall negative adjustment, recent negative adjustment, and other. Id. Mr. Hooten refused to sign each review. Id. Mr. Hooten added to the comments of his May 22, 2020: "Its been over a year since I got the A-102 5-16-19 when will it be off my recent history?" (errors in original). Id. at 53. However, each of these reviews shows that he had two other conduct violations in January 2020. Id. Mr. Hooten submitted a second classification appeal in June 2020,

arguing that it would benefit his mental health to be transferred to Indiana State Prison. Dkt. 57-1 at 34. This classification appeal was reviewed and denied by a non-party because this matter was "addressed by a prior classification appeal response." Id. at 33. Mr. Hooten then began receiving 30-day reviews and behavior modification plans from June 30 to December 10, 2020. Id. at 18, 21–22, 32, 38, 40. While many of these reviews mimicked the language and rationale from the 7-day reviews, the October 29, 2020, review revealed that Mr. Hooten had

been found guilty of a new conduct violation that took place on September 10, 2020. Id. at 38. Additionally, over the course of these reviews, Mr. Hooten was provided with Brief Intervention ToolS ("BITS") and guides to help him handle situations differently. Id. at 21 (July 31, 2020), 32 (December 10, 2020), 40 (September 30, 2020). Again, Mr. Hooten refused to sign any of these reviews. In August 2020, Wabash Valley staff conducted a classification hearing on Mr. Hooten's placement in ARSH which included input from a Casework

Manager, Custody Manager, OII/STG Coordinator, Unit Team Manager Snyder, Deputy Warden and the Warden. Id. at 81–82.

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HOOTEN v. BROWN, Counsel Stack Legal Research, https://law.counselstack.com/opinion/hooten-v-brown-insd-2025.