MARSHALL v. GEO GROUP INC

CourtDistrict Court, S.D. Indiana
DecidedMay 2, 2024
Docket1:23-cv-01456
StatusUnknown

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

Bluebook
MARSHALL v. GEO GROUP INC, (S.D. Ind. 2024).

Opinion

UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF INDIANA INDIANAPOLIS DIVISION

AUGUSTUS MARSHALL, ) ) Plaintiff, ) ) v. ) Case No. 1:23-cv-01456-TWP-KMB ) GEO GROUP INC, ) JENNIFER SMITH, Law Library Clerk and ) Notary, ) MARK SEVIER, Warden, ) WINNINGHAM, Ms., Grievance Specialist, ) JOHN DOE, Internal Affairs, ) ) Defendants. )

ORDER SCREENING COMPLAINTAND DIRECTING FURTHER PROCEEDINGS

This matter is before the Court for screening of Plaintiff Augustus Marshall's ("Mr. Marshall") Complaint (Dkt. 1). Mr. Marshal is a prisoner currently incarcerated at Westville Correctional Facility. He filed this civil action alleging wrongful confiscation of his educational materials while he was housed at New Castle Correctional Facility. Because Mr. Marshall is a "prisoner," this Court has an obligation to screen the Complaint before service on the Defendants. 28 U.S.C. § 1915A(a), (c). I. SCREENING STANDARD When screening a complaint, the Court must dismiss any portion that is frivolous or malicious, fails to state a claim for relief, or seeks monetary relief against a defendant who is immune from such relief. 28 U.S.C. § 1915A(b). To determine whether the complaint states a claim, the court applies the same standard as when addressing a motion to dismiss under Federal Rule of Civil Procedure 12(b)(6). See Schillinger v. Kiley, 954 F.3d 990, 993 (7th Cir. 2020). Under that standard, a complaint must include "enough facts to state a claim to relief that is plausible on its face." Bell Atl. Corp. v. Twombly, 550 U.S. 544, 570 (2007). "A claim has facial plausibility when the plaintiff pleads factual content that allows the court to draw the reasonable inference that the defendant is liable for the misconduct alleged." Ashcroft v. Iqbal, 556 U.S. 662, 678 (2009). The court construes pro se complaints liberally and holds them to a "less stringent

standard than formal pleadings drafted by lawyers." Cesal v. Moats, 851 F.3d 714, 720 (7th Cir. 2017). II. THE COMPLAINT Mr. Marshall names the following five defendants: GEO Group, Inc. ("Geo Group"), Law Library Clerk Jennifer Smith ("Ms. Smith"), Warden Mark Sevier ("Warden Sevier"), Grievance Specialist Winningham ("Ms. Winningham"), and John Doe from Internal Affairs. In his Complaint, Mr. Marshall alleges that on April 14, 2021, Ms. Smith wrongfully confiscated two educational business packets, informing Mr. Marshall that they appeared to be altered from their original state (Dkt. 1 at 5). The packets were sent to an unknown individual in Internal Affairs. These confiscated packets were exhibits to Mr. Marshall's motion for a sentence

modification, and the confiscation prevented him from filing his motion. Id. at 6. Internal Affairs never informed Mr. Marshall why the packets were taken, and they did not otherwise provide him due process. Id. at 7. On April 26, 2021, Mr. Marshall wrote to Internal Affairs about the issue. On April 29, 2021, Mr. Marshall wrote to Warden Sevier about the issue, and he did not respond. Id. at 9. Mr. Marshall also completed the grievance process and addressed the situation with Ms. Winningham. Id. Mr. Marshall eventually received photocopies of the materials, but they were unusable because only one side of the double-sided sheets had been copied. Id. at 11. Mr. Marshall continued to grieve the issue through September 2021. III. DISMISSAL OF COMPLAINT A. Untimeliness of Claims Based on April 2021 Events All claims based on events that occurred in April 2021 are dismissed as untimely. Untimeliness is an affirmative defense, but a claim may be dismissed sua sponte if "'the existence

of a valid affirmative defense is so plain from the face of the complaint that the suit can be regarded as frivolous.'" Muhammad–Ali v. Final Call, Inc., 832 F.3d 755, 763 (7th Cir. 2016) (quoting Walker v. Thompson, 288 F.3d 1005, 1009–10 (7th Cir. 2002)); see also Koch v. Gregory, 536 F. App'x 659, 660 (7th Cir. 2013) (when complaint's allegations plainly show it is untimely, dismissal under § 1915A is appropriate). "[I]n § 1983 actions, federal courts apply the statute of limitations governing personal injury actions in the state where the injury took place. In Indiana, such claims must be brought within two years." Serino v. Hensley, 735 F.3d 588, 590 (7th Cir. 2013) (citation omitted). And a claim accrues when "the plaintiff knows or has reason to know of the injury which is the basis of his action." Id. at 591.

Here, Mr. Marshall alleges a specific event that took place on April 14, 2021, when his educational materials were confiscated. Therefore, the statute of limitations for any claims based on that event began to run on April 14, 2021, regardless of whether Mr. Marshall suffered ongoing harm or injury from that action. Manuel v. City of Joliet, Ill., 903 F.3d 667, 669 (7th Cir. 2018) ("When a wrong is ongoing rather than discrete, the period of limitations does not commence until the wrong ends. Notice that we speak of a continuing wrong, not of continuing harm; once the wrong ends, the claim accrues even if that wrong has caused a lingering injury." (citation omitted; emphasis retained)). Therefore, Mr. Marshall's deadline to file a timely complaint based on these allegations was April 14, 2023. See Fed. R. Civ. P. 6(a)(1)(C). But his Complaint is signed August 8, 2023, and it was not filed with the Court until August 16, 2023. See Dkt. 1 at 13. All claims based on April 2021 events are therefore dismissed as untimely.

B. Deficiencies of Mr. Marshall's Allegations Even if Mr. Marshall's Complaint were not untimely, his claims are nevertheless subject to dismissal based on the screening standard set forth above. First, any claims against GEO Group are dismissed for failure to state a claim upon which relief can be granted. Private corporations acting under color of state law—including those that contract with the state to provide essential services to prisoners—are treated as municipalities for purposes of 42 U.S.C. § 1983 and can be sued when their actions violate the Constitution. Dean v. Wexford Health Sources, Inc., 18 F.4th 214, 235 (7th Cir. 2021) (citing Monell v. Dep't of Soc. Servs., 436 U.S. 658 (1978)). To state a Monell claim, the plaintiff must identify an action taken by the municipality and allege a causal link between the municipality's action and the deprivation

of federal rights. Dean, 18 F.4th at 235. "A municipality 'acts' through its written policies, widespread practices or customs, and the acts of a final decisionmaker." Levy v. Marion Co. Sheriff,

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MARSHALL v. GEO GROUP INC, Counsel Stack Legal Research, https://law.counselstack.com/opinion/marshall-v-geo-group-inc-insd-2024.