Jackson v. Lay

CourtDistrict Court, E.D. Arkansas
DecidedMay 10, 2023
Docket2:21-cv-00129
StatusUnknown

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

Bluebook
Jackson v. Lay, (E.D. Ark. 2023).

Opinion

IN THE UNITED STATES DISTRICT COURT EASTERN DISTRICT OF ARKANSAS DELTA DIVISION

ANDREW JACKSON PLAINTIFF ADC # 166861

v. 2:21CV00129-KGB-JTK

GAYLON LAY, et al. DEFENDANTS

PROPOSED FINDINGS AND RECOMMENDATIONS INSTRUCTIONS The following recommended disposition has been sent to United States District Judge Kristine G. Baker. Any party may file written objections to all or part of this Recommendation. If you do so, those objections must: (1) specifically explain the factual and/or legal basis for your objections; and (2) be received by the Clerk of this Court within fourteen (14) days of this Recommendation. By not objecting, you may waive the right to appeal questions of fact. DISPOSITION I. Introduction Andrew Jackson (“Plaintiff”) is confined in the East Arkansas Regional Unit (“EARU”) of the Arkansas Division of Correction (“ADC”). On September 9, 2021, Plaintiff filed this pro se action under 42 U.S.C. § 1983 against numerous ADC officials. (Doc. No. 2). Plaintiff also filed a Motion to Proceed In Forma Pauperis (“IFP Motion”), which was granted. (Doc. Nos. 6, 8). On May 1, 2023, this matter was reclassified as a “555” action for internal housekeeping purposes and was referred to the undersigned. (Doc. No. 7). The Court will now screen Plaintiff’s claims pursuant to the Prison Litigation Reform Act (“PLRA”) and in forma pauperis statute, as required. II. Screening The PLRA requires federal courts to screen prisoner complaints seeking relief against a governmental entity, officer, or employee. 28 U.S.C. ' 1915A(a). The Court must dismiss a complaint or portion thereof if the prisoner has raised claims that: (a) are legally frivolous or

malicious; (b) fail to state a claim upon which relief may be granted; or (c) seek monetary relief from a defendant who is immune from such relief. 28 U.S.C. ' 1915A(b). See also 28 U.S.C. § 1915(e) (screening requirements). An action is frivolous if “it lacks an arguable basis either in law or in fact.” Neitzke v. Williams, 490 U.S. 319, 325 (1989). Whether a plaintiff is represented by counsel or is appearing pro se, his complaint must allege specific facts sufficient to state a claim. See Martin v. Sargent, 780 F .2d 1334, 1337 (8th Cir.1985). An action fails to state a claim upon which relief can be granted if it does not plead “enough facts to state a claim to relief that is plausible on its face.” Bell Atlantic Corp. v. Twombly, 550 U.S. 544, 570 (2007).

In reviewing a pro se complaint under ' 1915(e)(2)(B), the Court must give the complaint the benefit of a liberal construction. Haines v. Kerner, 404 U.S. 519, 520 (1972). The Court must also weigh all factual allegations in favor of the plaintiff, unless the facts alleged are clearly baseless. Denton v. Hernandez, 504 U.S. 25, 32 (1992). III. Discussion A. Plaintiff’s Complaint Plaintiff sued: Warden Gaylon Lay; Deputy Wardens Michael Richardson and Jeremy Andrews; Director Dexter Payne; Former Director Wendy Kelley; Major Kenyan Randall; Captain Roosevelt Barden; Administrative Specialist Jacqueline Yarbough; Former Administrators Derrick Bailey and Jabreka Massey; K. Freeman; Arkansas Board of Corrections Secretary Tyrone Broomfield; Arkansas Board of Corrections Members John Felts, William Byers, Whitney Gass, and Lee Watson; Disciplinary Hearing Officer Janice Blake; Arkansas Board of Corrections Vice Chairman Bobby Glover; Arkansas Board of Corrections Chairman Benny Magness; the Arkansas

Board of Corrections; and unidentified Doe Defendants—all in their official and personal capacities. (Doc. No. 2 at 1-5). Plaintiff says that he was wrongfully convicted and sentenced to eight years in the ADC. (Id. at 7). Plaintiff did not get timely notice of the appellate decision affirming his conviction. (Id.). Once Plaintiff learned that his appeal had been denied, he sought the help of an attorney to assist with filing a state postconviction action to challenge the wrongful conviction. (Id.). As a result of Defendants’ allegedly unconstitutional policies, Defendants did not allow Plaintiff’s lawyer to bring into the prison legal documentation regarding the postconviction action, and Plaintiff was unable to receive phone calls from his lawyer in a timely manner. (Id. at 12). Because Plaintiff was unable to review and execute the documentation, Plaintiff postconviction petition was deemed deficient and was denied. (Id.). A United States

Magistrate Judge found Plaintiff was ineligible for habeas relief based on the fact that Plaintiff’s state postconviction petition was deemed deficient and denied by the state court. (Doc. No. 2 at 12). Plaintiff maintains that Defendants unlawful policies and actions violated Plaintiff’s right to access the courts and Plaintiff’s right to counsel. (Id.). Plaintiff also alleges that Defendants retaliated against him for his filing of an earlier lawsuit and grievances in early June 2021. (Id. at 13, 15). As a result of his engagement in protected activities, Plaintiff says Defendants seized an envelope that was clearly marked “Legal Mail” and that displayed the name, title, and address of Plaintiff’s attorney. (Id. at 13). Plaintiff alleged that Defendant Freeman “recorded the receipt of the legal mail and then proceeded to provide the envelope to Defendant Barden.” (Id. at 13). Defendant Barden then called Plaintiff “down to the main line under the pretense of distributing said legal mail.” (Id.). In Plaintiff’s presence, Defendant Barden opened the envelope, began to read the legal mail, then confiscated the mail because he did not recognize the sender as an attorney. (Doc. No. 2 at 13).

According to Plaintiff, that same day Plaintiff’s attorney called and spoke to Defendant Richardson, who confirmed the attorney was on Plaintiff’s mailing and visitation list. (Id.). Plaintiff’s attorney confirmed that he sent the mail at issue. (Id.). Nonetheless, Defendant Richardson feigned not being able to determine the lawyer’s identity as a pretext for retaliation. (Id.). Defendant Richardson also demanded that Plaintiff’s attorney divulge information protected by the attorney-client privilege. (Id. at 14). The attorney refused, after which Defendant Richardson said that he would not transmit the legal mail to Plaintiff. (Id.). Plaintiff’s attorney emailed Defendant Lay. (Id.). Sometime after, Plaintiff was called to the Warden’s office where Defendants Richardson and Barden threatened Plaintiff with a major disciplinary if he did not disclose information protected by the attorney-client privilege. (Id.). Plaintiff refused

and received a major disciplinary charge that was approved by Defendant Randall. (Doc. No. 2 at 14). After a disciplinary hearing on June 18, 2021: Plaintiff’s class was reduced; he was restricted from commissary, phone, and visitation for 90 days; he lost his card privileges; he was reassigned to a barracks “reserved for the unit’s most violent and dangerous offenders”; he was placed in the hole without air conditioning for several days; and Plaintiff was reassigned to the hoe squad from his kitchen job. (Id. at 15). Plaintiff says these actions were taken by each Defendant in retaliation for Plaintiff filing grievances in June 2021, and to intimidate Plaintiff so he would refrain from accessing the court. (Id. at 16).

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Bluebook (online)
Jackson v. Lay, Counsel Stack Legal Research, https://law.counselstack.com/opinion/jackson-v-lay-ared-2023.