Joseph Deion Page v. Shawn1 Phillips, et al.

CourtDistrict Court, E.D. Tennessee
DecidedMarch 19, 2026
Docket3:26-cv-00038
StatusUnknown

This text of Joseph Deion Page v. Shawn1 Phillips, et al. (Joseph Deion Page v. Shawn1 Phillips, et al.) is published on Counsel Stack Legal Research, covering District Court, E.D. Tennessee primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Joseph Deion Page v. Shawn1 Phillips, et al., (E.D. Tenn. 2026).

Opinion

UNITED STATES DISTRICT COURT EASTERN DISTRICT OF TENNESSEE AT KNOXVILLE

JOSEPH DEION PAGE, ) ) Case No. 3:26-cv-38 Plaintiff, ) ) Judge Travis R. McDonough v. ) ) Magistrate Judge Debra C. Poplin SHAWN1 PHILLIPS, et al., ) ) Defendants. )

MEMORANDUM & ORDER

Joseph Deion Page, a prisoner in the custody of the Tennessee Department of Correction (“TDOC”) housed at the Morgan County Correctional Complex (“MCCX”), filed a pro se civil rights complaint in the United States District Court for the Middle District of Tennessee (Doc. 1). After granting Plaintiff’s in forma pauperis application and dismissing Defendants TDOC, the Tennessee Board of Parole and Pardons, and Commissioner Frank Strada, the Middle District transferred the action to this Court. (See Docs. 18, 19.) Plaintiff’s complaint (Doc. 1) is now before the Court for screening in compliance with the Prison Litigation Reform Act (“PLRA”), 28 U.S.C. §§ 1915(e)(2)(B) and 1915A, to determine whether it states a justiciable claim. Also before the Court are Plaintiff’s motions for a preliminary injunction (Doc. 3), to appoint counsel (Doc. 10), to require the United States Marshal Service (“USMS”) to serve process (Doc. 11), to supplement his complaint (Doc. 13), and to toll the statute of limitations (Doc. 22). For the reasons set forth below, the Court will grant Plaintiff’s motion to supplement his complaint (Doc. 13), deny his remaining motions

1 The Clerk will be DIRECTED to update the docket to reflect the correct spelling of Defendant Phillips’ first name as “Shawn.” (See Doc. 18, at 8 (granting motion at Doc. 16).) (Doc. 3, 10, 11, 22), order Plaintiff to complete the portion of his complaint demanding relief, permit certain federal claims to proceed against Defendants Stacey Oakes and Brandy Hutson in their individual capacities, and dismiss all remaining claims and Defendants. I. PLAINTIFF’S MOTIONS A. Preliminary Injunction In his “Motion for Preliminary Injunction[,]” Plaintiff asks the Court to enjoin TDOC to release Plaintiff on parole because (1) he is housed in conditions imposing a “significant and atypical hardship”; (2) his unidentified “serious medical needs” are not being met in TDOC

custody; and (3) “[t]wo ranking officers unconstitutionally deprived Plaintiff of his liberty by conspiring on a course of action with the knowledge and intention that their actions would cause injury to Plaintiff.” (Doc. 3, at 1–2.) Plaintiff’s motion is governed by Rule 65 of the Federal Rules of Civil Procedure. Fed. R. Civ. P. 65. Because Plaintiff filed the instant motion before any Defendant has been served, the Court treats it as a motion for a temporary restraining order (“TRO”).2 See Fed. R. Civ. P. 65(b). In determining whether to grant a TRO, courts balance the following factors: “(1) whether the movant has shown a strong likelihood of success on the merits; (2) whether the movant will suffer irreparable harm if the injunction is not issued; (3) whether the issuance of the injunction would cause substantial harm to others; and (4) whether the public interest would be served by issuing the injunction.” Overstreet v. Lexington-Fayette Urban Cnty. Gov’t, 305 F.3d 566, 573 (6th Cir. 2002) (citations omitted). The first factor, likelihood of success on the merits,

is the most important factor and typically determines the outcome of the motion. See Obama for

2 The Court notes that the factors to be considered in determining whether to issue a TRO or preliminary injunction are the same. See, e.g., Workman v. Bredesen, 486 F.3d 896, 904–05 (6th Cir. 2007). America v. Husted, 697 F.3d 423, 436 (6th Cir. 2012). Even where success on the merits is shown, however, injunctive relief is “an extraordinary remedy never awarded as of right.” Winter v. Nat’l Res. Def. Council, Inc., 555 U.S. 7, 24 (2008) (citation omitted). Rather, it “should be granted only if the movant carries his or her burden of proving that the circumstances clearly demand it.” Overstreet, 305 F.3d at 573 (citation omitted).

Here, Plaintiff is essentially asking the Court to provide him relief as though he has already prevailed on the merits of this case. However, the purpose of injunctive relief is to maintain the parties’ positions until they can be heard on their merits at trial. See University of Texas v. Camenisch, 451 U.S. 390, 395 (1981). And Plaintiff’s motion contains no facts that would suggest that he has a strong likelihood of success on the merits. In fact, in the instant motion, he offers no facts describing his medical needs, current conditions, or alleged deprivation of liberty at all. Thus, at this juncture, Plaintiff’s ability to prove any constitutional violation at all is speculative. Therefore, Plaintiff has not demonstrated a strong likelihood of success on the merits of his claims.

Because Plaintiff has failed to demonstrate a likelihood of success on the merits of his claim, the Court cannot assume he will face irreparable harm absent injunctive relief. See, e.g., Overstreet, 305 F.3d at 578 (denying plaintiff’s argument that he is entitled to presumption of irreparable harm absent showing of likelihood of success on the merits). Additionally, there is a strong public interest in leaving the administrative matters of state prisons in the hands of jail officials. McCord v. Maggio, 910 F.2d 1248, 1250 (1990) (holding prisoner housing is a matter squarely within the “broad discretion” of prison officials, “free from judicial intervention” except in extreme circumstances). In fact, “[a]ny interference by the federal courts in the administration of state prison matters is necessarily disruptive. The public welfare therefore militates against the issuance of extraordinary relief in the prison context, absent a sufficient showing of a violation of constitutional rights.” Johnson v. Payton, No. 13-11437, 2013 WL 1843979, *3 (E.D. Mich. Apr. 10, 2013) (citing Glover v. Johnson, 855 F.2d 277, 286-87 (6th Cir. 1988)), report and recommendation adopted, No. 13-11437, 2013 WL 1843971 (E.D. Mich. May 1, 2013). Therefore, the remaining factors also weigh against the

grant of injunctive relief in this cause, and Plaintiff’s motion for same (Doc. 3) will be denied.3 B. Appointment of Counsel Plaintiff requests the Court appoint him counsel to represent him in this action due to his lack of higher education and legal knowledge, the complex nature of his claims, his limited access to the law library, and the fact that he is an Illinois resident seeking to raise claims under both federal and Tennessee law. (See Doc. 10.) “The court may request an attorney to represent any person unable to afford counsel.” 28 U.S.C. § 1915(e)(1) (emphasis added). However, “[a]ppointment of counsel in a civil case is not a constitutional right[,]” but rather a “privilege that is justified only by exceptional circumstances.” Lavado v. Keohane, 992 F.2d 601, 605–06 (6th Cir. 1993) (citations omitted). In determining whether “exceptional circumstances” exist, the Court considers “the complexity

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Bluebook (online)
Joseph Deion Page v. Shawn1 Phillips, et al., Counsel Stack Legal Research, https://law.counselstack.com/opinion/joseph-deion-page-v-shawn1-phillips-et-al-tned-2026.