John Andrew Kister v. Warden McKee and ADOC Employee in Charge of the Commissary Statewide

District Court, M.D. Alabama·Decided August 11, 2026·No. 2:26-cv-00580·Unknown

Opinion

IN THE UNITED STATES DISTRICT COURT FOR THE MIDDLE DISTRICT OF ALABAMA NORTHERN DIVISION

JOHN ANDREW KISTER, ) AIS # 264274, ) ) Plaintiff, ) ) v. ) CASE NO. 2:26-CV-580-WKW ) [WO] WARDEN McKEE and ADOC ) EMPLOYEE IN CHARGE OF THE ) COMMISSARY STATEWIDE, ) ) Defendants. )

MEMORANDUM OPINION AND ORDER I. INTRODUCTION Plaintiff John Andrew Kister, an inmate in the custody of the Alabama Department of Corrections (ADOC), filed this pro se 42 U.S.C. § 1983 complaint against two Defendants: Warden McKee and the ADOC employee in charge of the commissary statewide. (Doc. # 1.) The complaint is before the court for screening under 28 U.S.C. §§ 1915(e)(2)(B) and 1915A. For the following reasons, Plaintiff’s complaint will be dismissed without prejudice. II. STANDARD OF REVIEW Plaintiff, a prisoner, is proceeding in forma pauperis (IFP). (Doc. # 6.) Under the IFP provisions of § 1915, any complaint filed is subject to mandatory court review. The complaint also is subject to screening under § 1915A. Sections 1915 and 1915A require the court to dismiss a complaint, or any part of it, on its own initiative, if the allegations are frivolous, fail to state a claim on which relief may be

granted, or seek monetary relief from a defendant who is immune from such relief. § 1915(e)(2)(B)(i)–(iii); § 1915A(b)(1)–(2).1 A complaint must be dismissed at the statutory screening stage if it fails to

state a claim upon which relief may be granted. See § 1915(e)(2)(B)(ii); § 1915A(b)(1). This review follows the same standard governing dismissals for failure to state a claim under Rule 12(b)(6) of the Federal Rules of Civil Procedure. See Douglas v. Yates, 535 F.3d 1316, 1320 (11th Cir. 2008). Hence, to state a claim

upon which relief may be granted, “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 Bell Atl. Corp. v. Twombly, 550

U.S. 544, 570 (2007)). The plausibility standard “asks for more than a sheer possibility that a defendant has acted unlawfully.” Id. To meet the plausibility standard, the plaintiff must plead factual content that “allows the court to draw the reasonable inference that the defendant is liable for the misconduct alleged.” Id. The

1 The language in § 1915(e)(2)(B)(i)–(iii) is nearly identical to the language in § 1915A(b)(1)–(2). The Eleventh Circuit applies the same standards when evaluating complaints under both statutes. See Hutchinson v. Wexford Health Servs., Inc., 638 F. App’x 930, 932 (11th Cir. 2016) (per curiam) (observing that even if the district court had screened the complaint under the wrong statute, the outcome would be the same because the standards under §§ 1915(e)(2)(B) and 1915A(b) are effectively identical). Therefore, this court applies the Eleventh Circuit’s interpretation of one statute to the other. allegations must present a “plain statement possessing enough heft to show that the pleader is entitled to relief.” Twombly, 550 U.S. at 557 (cleaned up). “Threadbare

recitals of the elements of a cause of action, supported by mere conclusory statements, do not suffice.” Iqbal, 556 U.S. at 678. Pro se pleadings are liberally construed and held “to less stringent standards”

than pleadings drafted by attorneys. Bilal v. Geo Care, LLC, 981 F.3d 903, 911 (11th Cir. 2020) (quoting Erickson v. Pardus, 551 U.S. 89, 94 (2007)). However, the court cannot “rewrite an otherwise deficient pleading [by a pro se litigant] in order to sustain an action.” GJR Invs. v. Escambia Cnty., 132 F.3d 1359, 1369 (11th Cir.

1998), overruled on other grounds by Iqbal, 556 U.S. 662. III. THE COMPLAINT’S ALLEGATIONS In his complaint, Plaintiff alleges ongoing disparate treatment of mentally ill

prisoners confined in the Residential Housing Unit (RHU) at Bullock Correctional Facility. Plaintiff contends that he and other prisoners in the RHU, all of whom have “serious mental illnesses,” are restricted to three tobacco items and six bags of coffee per week whereas general-population inmates are limited to nine tobacco products

and ten coffees per week. (Doc. # 1 at 4.) He further contends that the greater restriction placed on RHU inmates amounts to discrimination based on those inmates’ mental illness. (Id.) Plaintiff argues that Warden McKee is aware of the restriction and could remove it at any time. He also argues that the ADOC employee in charge of the

commissary statewide has the final say in commissary restrictions and could remove restrictions at any time. (Id.) As relief, he requests (1) $5,000 in compensatory damages, (2) $5,000 in punitive damages, and (3) that the restriction on RHU

prisoners be made even with the general-population prisoners. (Id. at 5.) IV. DISCUSSION Plaintiff brings this action under 42 U.S.C. § 1983, which provides: Every person who, under color of any statute, ordinance, regulation, custom, or usage, of any State or Territory or the District of Columbia, subjects, or causes to be subjected, any citizen of the United States or other person within the jurisdiction thereof to the deprivation of any rights, privileges, or immunities secured by the Constitution and laws, shall be liable to the party injured in an action at law, suit in equity, or other proper proceeding for redress . . . .

To state a claim under § 1983, a plaintiff must allege two elements: First, he must allege a violation of a right protected by federal laws; second, he must allege that the violation was committed by a person acting under color of law. See West v. Atkins, 487 U.S. 42, 48 (1988); accord Beaubrun v. Dodge State Prison, 2025 WL 2490396, at *3 (11th Cir. Aug. 29, 2025) (per curiam). A. Equal Protection Claim

Liberally construing the complaint, Plaintiff seems to allege a violation of his equal protection rights afforded to him by the Fourteenth Amendment to the United States Constitution.2 The Fourteenth Amendment’s Equal Protection Clause guarantees that no state shall “deny to any person within its jurisdiction the equal

protection of the laws.” U.S. Const. amend. XIV, § 1. To state an equal protection claim, an inmate-plaintiff generally must allege “that (1) he is similarly situated to other prisoners who received more favorable treatment; and (2) the state engaged in

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John Andrew Kister v. Warden McKee and ADOC Employee in Charge of the Commissary Statewide, (M.D. Ala. 2026).

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