Langley v. Little

CourtDistrict Court, D. Idaho
DecidedSeptember 28, 2021
Docket1:21-cv-00181
StatusUnknown

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

Bluebook
Langley v. Little, (D. Idaho 2021).

Opinion

UNITED STATES DISTRICT COURT

FOR THE DISTRICT OF IDAHO

BRIAN LANGLEY,

Plaintiff, Case No. 1:21-cv-00181-BLW

vs. INITIAL REVIEW ORDER BY SCREENING JUDGE BRAD LITTLE; IDAHO STATE BOARD OF CORRECTION GOVERNING MEMBERS; DIRECTOR IDOC JOSH TEWALT, and EXECUTIVE DIRECTOR ASHLEY DOWELL,

Defendants.

Plaintiff Brian Langley filed a prisoner civil rights action to challenge the Idaho Department of Correction’s (IDOC) method of preparing inmates for parole and the Idaho Commission of Pardons and Parole’s (ICPP) decision to deny him parole after he served the fixed portion of his sentence. (Dkt. 1.) Plaintiff’s Complaint was conditionally filed by the Clerk of Court due to his status as a prisoner. A “conditional filing” means that Plaintiff must obtain authorization from the Court to proceed. After reviewing the

INITIAL REVIEW ORDER BY SCREENING JUDGE - 1 Complaint, the Court has determined that it will be dismissed with leave to amend and that class action status will not be granted. REVIEW OF COMPLAINT

1. Standard of Review Under modern pleading standards, Federal Rule of Civil Procedure 8 requires a complaint to “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 Atlantic Corp. v. Twombly, 550 U.S. 544, 570 (2007)). The Iqbal/Twombly “facial

plausibility” standard is met when a complaint contains “factual content that allows the court to draw the reasonable inference that the defendant is liable for the misconduct alleged.” Id., citing Twombly, 550 U.S. at 556. A plaintiff must provide sufficient factual allegations to show that there is “more than a sheer possibility that a defendant has acted unlawfully.” Ibid. “Where a complaint pleads facts that are ‘merely consistent with’ a

defendant’s liability, it ‘stops short of the line between possibility and plausibility of ‘entitlement to relief.’” Ibid. Stated differently, Rule 8 “demands more than an unadorned, the-defendant- unlawfully-harmed-me accusation.” Iqbal, 556 U.S. at 678. Bare allegations that amount to merely a restatement of the elements of a cause of action, without adequate factual

support, are not enough to withstand a Federal Rule of Civil Procedure 12(b)(6) challenge for dismissal for failure to state a claim upon which relief can be granted. See id.

INITIAL REVIEW ORDER BY SCREENING JUDGE - 2 In addition, the Prison Litigation Reform Act (PLRA)1requires the Court to screen all pro se prisoner and pauper complaints to determine whether they have stated a claim upon which relief can be granted before such complaints are served on the defendants. 28

U.S.C. §§ 1915 & 1915A. The Court must dismiss any claims that do not have adequate factual support or are frivolous or malicious. 28 U.S.C. § 1915(e)(2)(B). The Court also must dismiss claims that fail to state a claim upon which relief may be granted or that seek monetary relief from a defendant who is immune from such relief. Id. These last two categories—together with claims that fall outside the federal court’s

narrow grant of jurisdiction—encompass those claims that may (or may not) have factual support, but nevertheless are barred by a well-established legal rule. The Court liberally construes a plaintiff’s pleadings to determine whether the case should be dismissed for a failure to plead sufficient facts to support a cognizable legal theory or for the absence of a cognizable legal theory. The critical inquiry is whether a

constitutional claim, however inartfully pleaded, has an arguable factual and legal basis. See Jackson v. Arizona, 885 F.2d 639, 640 (9th Cir. 1989).2 Rule 12(b)(6) authority to dismiss claims as explained in Jackson was expanded by the PLRA, giving courts power to dismiss deficient claims sua sponte, either before or after opportunity to amend as explained in Lopez v. Smith, 203 F.3d 1122, 1130 (9th Cir. 2000).

1 Pub. L. No. 104-134, 110 Stat. 1321, as amended, 42 U.S.C. § 1997e, et seq.

2 Jackson was superseded by statute on other grounds as stated in Lopez v. Smith, 203 F.3d 1122, 1130 (9th Cir. 2000).

INITIAL REVIEW ORDER BY SCREENING JUDGE - 3 Plaintiff brings claims under 42 U.S.C. § 1983, the civil rights statute. To state a claim under § 1983, a plaintiff must allege a violation of rights protected by the Constitution or created by federal statute proximately caused by conduct of a person

acting under color of state law. Crumpton v. Gates, 947 F.2d 1418, 1420 (9th Cir. 1991). For Plaintiff’s purposes, 42 U.S.C. § 1983 is an implementing statute that makes it possible to bring a cause of action under the Amendments of the United States Constitution. 2. Background

Plaintiff alleges that he completed the fixed portion of his criminal sentence, making him parole-eligible, but that the ICPP denied him parole. He is now serving the indeterminate portion of his sentence. He has filed self-initiated progress reports yearly, but has yet to be paroled. He asserts that prison officials have received funding to use for prisoner rehabilitation and parole supervision, but that they have not implemented aids to

help prisoners qualify for parole. He brings claims upon a variety of legal theories against the officials charged with prisoner programming and parole decisionmaking in the state of Idaho. 3. Due Process Claim (¶¶ 22) The Due Process Clause of the Fourteenth Amendment prohibits state action that

deprives a person of life, liberty, or property without due process of law, but a person cannot bring a due process claim unless he demonstrates that he was deprived of one of

INITIAL REVIEW ORDER BY SCREENING JUDGE - 4 these protected interests. Kentucky Dep’t of Corr. v. Thompson, 490 U.S. 454, 459-60 (1989). Here, while Plaintiff sets forth compelling philosophical, practical, and logical reasons why society should provide timely rehabilitative treatment to inmates to prepare

them for parole upon eligibility and why the state’s parole preparation resources and decision-making processes should be revamped to meet this goal, there is no adequate legal basis for bringing such claims in federal court. There is “no right under the Federal Constitution to be conditionally released before the expiration of a valid sentence, and the States are under no duty to offer parole

to their prisoners.” See Swarthout v. Cooke, 562 U.S. 216, 220 (2011); Board of Pardons v. Allen, 482 U.S. 369, 380-81 (1987). Therefore, an inmate can bring a procedural due process challenge to a parole denial decision only when there is a state-created liberty interest in parole. Swarthout, 562 U.S. at 220.

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Langley v. Little, Counsel Stack Legal Research, https://law.counselstack.com/opinion/langley-v-little-idd-2021.