MAYFIELD v. WIRE

CourtDistrict Court, S.D. Indiana
DecidedJanuary 4, 2022
Docket2:19-cv-00335
StatusUnknown

This text of MAYFIELD v. WIRE (MAYFIELD v. WIRE) 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
MAYFIELD v. WIRE, (S.D. Ind. 2022).

Opinion

UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF INDIANA TERRE HAUTE DIVISION

CAMERON MAYFIELD, ) ) Plaintiff, ) ) v. ) No. 2:19-cv-00335-JRS-MG ) DAVID WIRE, et al. ) ) Defendants. )

ORDER GRANTING DEFENDANTS' MOTION FOR SUMMARY JUDGMENT AND DIRECTING ENTRY OF FINAL JUDGMENT

Plaintiff Cameron Mayfield filed this lawsuit when he was an inmate of the Indiana Department of Correction ("IDOC") at Wabash Valley Correctional Facility ("WVCF"). He alleges that his rights were violated during disciplinary proceedings at that facility. Specifically, Mr. Mayfield claims that his federal due process rights were violated and that he was subjected to false imprisonment in violation of Indiana law.1 The defendants move for summary judgment on Mr. Mayfield's claims. For the following reasons, the motion for summary judgment is GRANTED as to Mr. Mayfield's due process claim and Mr. Mayfield's state law claim is dismissed without prejudice. I. Summary Judgment Standard Summary judgment shall be granted "if the movant shows that there is no genuine dispute as to any material fact and the movant is entitled to judgment as a matter of law." Fed. R. Civ. P. 56(a). The moving party must inform the court "of the basis for its motion" and specify evidence demonstrating "the absence of a genuine issue of material fact." Celotex Corp. v. Catrett, 477 U.S.

1 Mr. Mayfield's other state law claims were previously dismissed. Dkt. 48. 317, 323 (1986). Once the moving party meets this burden, the nonmoving party must "go beyond the pleadings" and identify "specific facts showing that there is a genuine issue for trial." Id. at 324. In ruling on a motion for summary judgment, the Court views the evidence "in the light most favorable to the non-moving party and draw[s] all reasonable inferences in that party's favor."

Zerante v. DeLuca, 555 F.3d 582, 584 (7th Cir. 2009) (citation omitted). II. Facts Because the defendants have moved for summary judgment under Rule 56(a), the Court views and recites the evidence "in the light most favorable to the non-moving party and draw[s] all reasonable inferences in that party's favor." Id. In April of 2016, defendant David Wire investigated an assault Mr. Mayfield committed on a correctional officer and concluded that Mr. Mayfield "committed the act of False Reporting of the commission of a crime to a sworn police officer in retaliation against correctional staff." Dkt. 112-1 at 5-6. On May 12, 2016, defendant D. Hughett conducted the disciplinary hearing and Mr. Mayfield was found guilty of offense 100, violation of law and sanctioned with 365 days in

disciplinary segregation, among other things. Dkt. 112-2 Id. at 2. Mr. Mayfield appealed, and defendant Warden Smith denied the appeal. Id. at 1. Mr. Mayfield later received a rehearing and was found guilty of offense 100. Dkt. 112-1 at 2. His appeal of that finding was granted in part and denied in part and the underlying offense was amended from 100 to C-350 and the sanctions were amended to non-grievous sanctions. Dkt. 1 at 10-11. Mr. Mayfield's appeal of that decision was denied. Dkt. 1 at 10, 11. Mr. Mayfield spent a total of 105 days in disciplinary segregation. Dkt. 1 at 13. III. Discussion The defendants seek summary judgment on several grounds, which can be summarized as follows: (1) Mr. Mayfield cannot bring a civil rights lawsuit under 42 U.S.C. § 1983 because success in this lawsuit would necessarily imply the invalidity of the disciplinary conviction; (2)

any due process violation was cured by the rehearing, which provided him adequate due process; (3) Mr. Mayfield did not have a liberty interest in being free from a short period of disciplinary segregation; and (4) Mr. Mayfield was not falsely imprisoned. Mr. Mayfield's due process claim can be resolved on the ground that he did not have a liberty interest in avoiding 105 days in disciplinary segregation and the Court need not address the defendants' other grounds. Further, because Mr. Mayfield's federal claim has been resolved, the Court declines to exercise supplemental jurisdiction over his state law false imprisonment claim. A. Due Process The Due Process Clause applies only to deprivations of life, liberty, and property. Isby v. Brown, 856 F.3d 508, 524 (7th Cir. 2017). Generally, "inmates have no liberty interest in avoiding

transfer to discretionary segregation—that is, segregation imposed for administrative, protective, or investigative purposes." Townsend v. Fuchs, 522 F.3d 765, 771 (7th Cir. 2008) (citing Lekas v. Briley 405 F.3d 602, 609 (7th Cir. 2005)). A protected liberty interest "is triggered only when the confinement imposes 'atypical and significant hardship on the inmate in relation to the ordinary incidents of prison life.'" Lisle v. Welborn, 933 F.3d 705, 721 (7th Cir 2019) (quoting Sandin v. Conner, 515 U.S. 472, 484 (1995)). "When considering whether disciplinary segregation imposes atypical and significant hardships, [the Court looks] to both the duration of the segregation and the conditions endured." Id. (citing Marion v. Columbia Correction Inst., 559 F.3d 693, 697 (7th Cir. 2009)). The Seventh Circuit has "found that, depending on the conditions of confinement and whether there were any additional punishments, a period of segregation … shorter than four months may" be an atypical and significant hardship. Lisle, 933 F.3d at 721 (citing Kervin v. Barnes, 787 F.3d 833, 836 (7th Cir. 2015)). But the court has found that some longer durations in

confinement are not. Id. (citing Marion, 559 F.3d at 698). Mr. Mayfield was in segregation for over three months, but the length of time he was in segregation on its own is not enough to trigger due process. See Davidson v. Uchtman, 2006 WL 2349643, at * 2 (S.D. Ill. Aug. 11, 2006) (nine months in disciplinary segregation did not state a due process violation). To succeed on his claim, Mr. Mayfield must show that the conditions of confinement during those 105 days were atypical and created significant hardship. See Lisle, 933 F.3d at 721. "In short, if the disciplinary measures do not 'substantially worsen the conditions of confinement" of an inmate, then he has not been deprived of a protected liberty interest." Id. (citing Miller v. Dobier, 634 F.3d 412, 414-15 (7th Cir. 2011)). There is little evidence in the record regarding the conditions Mr. Mayfield experienced in segregation. See id. at 721 ("Lisle needed to show that the

conditions of his confinement in his segregated cell deviated substantially from the ordinary conditions of prison life.") (citing cases). As the plaintiff, it is Mr. Mayfield's burden to show that his due process rights were violated. Accordingly, for purposes of his motion for summary judgment, he must present evidence that shows he is entitled to judgment as a matter of law. Bunch v. United States, 880 F.3d 938

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MAYFIELD v. WIRE, Counsel Stack Legal Research, https://law.counselstack.com/opinion/mayfield-v-wire-insd-2022.