Justice v. Property C.O. Aaron Belanger

CourtDistrict Court, D. New Hampshire
DecidedJuly 10, 2025
Docket1:23-cv-00308
StatusUnknown

This text of Justice v. Property C.O. Aaron Belanger (Justice v. Property C.O. Aaron Belanger) is published on Counsel Stack Legal Research, covering District Court, D. New Hampshire primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Justice v. Property C.O. Aaron Belanger, (D.N.H. 2025).

Opinion

UNITED STATES DISTRICT COURT FOR THE DISTRICT OF NEW HAMPSHIRE

William Soler Justice

v. Case No. 23-cv-308-SE-AJ

Aaron Belanger Eric Barbaro

Order Adopting in Part and Rejecting in Part the Report and Recommendation William Soler Justice alleges the following facts in his complaint. On April 9, 2020, while civilly committed at the New Hampshire Department of Corrections’ Secure Psychiatric Unit (SPU), he overheard a correctional officer, Aaron Belanger, say something about Belanger’s sister. In response, Justice asked Belanger for the name of his sister. When Belanger did not respond, Justice repeated the question multiple times. Eventually, Belanger told Justice he was “being disrespectful,” ordered him to “lockdown,” and then escorted him there. Doc. no. 1 at 4. Justice complied without issue. About an hour later, Sergeant Eric Barbaro, another officer in the SPU, ordered Justice to be removed to the E Ward, which Justice described as being in lockdown for 23 hours each day. After spending approximately a week in the E Ward, Justice was moved to the F Ward, where he spent another week. Justice described both wards as being “involuntarily seclusive.” Id. When Justice returned from the E and F Wards, he noticed that some of his property was missing. He believes that Belanger took this property. Representing himself, Justice filed a complaint in this court alleging claims against Belanger and Barbaro for violating his due process rights when they placed him in the E and F Wards and for failing to return his property that went missing while he was in the E and F Wards. The magistrate judge’s report and recommendation (“R&R”) after preliminary review of Justice’s complaint concluded that Justice’s two weeks in the E and F Wards did not rise to the level of a cognizable injury. Doc. no. 6 at 4–5 (citing Sandin v. Conner, 515 U.S. 472, 486 (1995) and Richardson v. Runnels, 594 F.3d 666, 672 (9th Cir. 2010)). As for Justice’s claim involving his property, the Magistrate Judge explained that the Board of Claims, New Hampshire’s complaint system for prisoners with lost or stolen property, provided Justice with sufficient

process. The R&R thus recommended that the court dismiss Justice’s complaint. Justice objected to the R&R, seeking “to assert all [his] due process claims.” Doc. no. 7 at 1. He mainly focused on his time in the E and F Wards, which he described as “solitary confinement.” Id. Justice also explained that he never received “a disciplinary hearing or even an explanation of the reason for” his removal to the wards. Id. For the reasons stated herein, the court adopts the R&R to the extent that it recommends dismissal without prejudice of the property-related claim, but it does not adopt the R&R to the extent that it recommends dismissal of the claims involving Justice’s time on the E and F Wards.

Standard of Review When a plaintiff, like Justice, commences an action pro se and in forma pauperis, the magistrate judge is directed to conduct preliminary review. See LR 4.3(d); see also 28 U.S.C. §§ 1915(e)(2), 1915A. On preliminary review, the magistrate judge may report and recommend to the court that one or more claims should be dismissed if, among other reasons, they are frivolous or malicious, fail to state a claim upon which relief can be granted, seek damages from defendants who are immune from such relief, or the court lacks jurisdiction. See id.; see also 28 U.S.C. § 1915(e)(2). Because Justice is representing himself, the court “liberally construe[s]” his complaint. Erickson v. Pardus, 551 U.S. 89, 94 (2007) (quotation omitted). Disregarding any legal conclusions, the court considers whether the factual content in the complaint and inferences reasonably drawn therefrom, taken as true, state a facially plausible claim to relief. Hernandez- Cuevas v. Taylor, 723 F.3d 91, 102-03 (1st Cir. 2013) (citing Ashcroft v. Iqbal, 556 U.S. 662, 678 (2009)).When a party objects to a magistrate judge’s proposed findings and recommendations with respect to a dispositive pretrial matter, the court makes a de novo determination. 28 U.S.C.

§ 636(b)(1); Fed. R. Civ. P. 72(b)(3).

Discussion Construed liberally, Justice’s complaint alleges three claims, each of which he brings under 42 U.S.C. § 1983 against the defendants in their personal capacity.1 Justice’s first claim alleges that the two weeks he spent in involuntary seclusion violated his Fourteenth Amendment substantive due process rights not to be punished (Count I). His second claim alleges that Belanger and Barbaro violated his Fourteenth Amendment procedural due process rights by sending him to involuntary seclusion without providing him a reason or an opportunity to

challenge the decision (Count II). Finally, his third claim alleges that Belanger violated his Fourteenth Amendment due process rights when he took Justice’s property (Count III). The court begins with Justice’s substantive due process claim. In evaluating Justice’s complaint, the R&R correctly noted that plaintiffs who have been civilly committed are entitled to “more considerate treatment and conditions of confinement” than those who are incarcerated following criminal conviction. Doc. no. 6 at 4 (quoting Youngberg v. Romeo, 457 U.S. 307, 321–

1 A damages suit against the officers in their official capacity would be a “suit against the governmental entity itself.” Surprenant v. Rivas, 424 F.3d 5, 19 (1st Cir. 2005). To prove such a case, Justice would need to plead facts evincing a policy, custom, or practice. See id. He has not done so. The court therefore does not construe his allegations as against the officers in their official capacity. 22 (1982)). But the R&R then relied on cases involving convicted individuals to support its recommendation that Justice’s alleged injury was de minimis and insufficient to state a claim under the Fourteenth Amendment. Instead, in the civil commitment context, individuals have a substantive due process right to be free from punishment for the reason underlying their commitment. See Healey v. Spencer,

765 F.3d 65, 78 (1st Cir. 2014). However, not every disagreeable condition is considered punishment in the constitutional sense. See id. When determining whether conditions are unconstitutionally punitive, the court must consider whether the alleged conditions “bear some reasonable relation to the purposes for which persons are committed” and whether the defendants “failed to exercise reasonable professional judgment.” Id. Justice’s complaint allows the inference that the defendants sent Justice to the E and F Wards in retaliation for pestering Belanger. Moreover, Justice describes the two weeks he spent in the wards as involuntary seclusion. In his objection to the R&R, Justice illuminates this description, alleging that his time in the E and F Wards amounted to solitary confinement. At this

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Related

Youngberg v. Romeo Ex Rel. Romeo
457 U.S. 307 (Supreme Court, 1982)
Hudson v. Palmer
468 U.S. 517 (Supreme Court, 1984)
Sandin v. Conner
515 U.S. 472 (Supreme Court, 1995)
Erickson v. Pardus
551 U.S. 89 (Supreme Court, 2007)
Ashcroft v. Iqbal
556 U.S. 662 (Supreme Court, 2009)
Surprenant v. Rivas
424 F.3d 5 (First Circuit, 2005)
Wilkinson v. Austin
545 U.S. 209 (Supreme Court, 2005)
Hernandez-Cuevas v. Taylor
723 F.3d 91 (First Circuit, 2013)
Richardson v. Runnels
594 F.3d 666 (Ninth Circuit, 2010)
Healey v. Dennehy
765 F.3d 65 (First Circuit, 2014)

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Justice v. Property C.O. Aaron Belanger, Counsel Stack Legal Research, https://law.counselstack.com/opinion/justice-v-property-co-aaron-belanger-nhd-2025.