McDermott v. Idaho Department of Corrections

CourtDistrict Court, D. Idaho
DecidedDecember 2, 2024
Docket1:24-cv-00140
StatusUnknown

This text of McDermott v. Idaho Department of Corrections (McDermott v. Idaho Department of Corrections) 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
McDermott v. Idaho Department of Corrections, (D. Idaho 2024).

Opinion

UNITED STATES DISTRICT COURT FOR THE DISTRICT OF IDAHO

JASON RYAN McDERMOTT, #62020, Case No. 1:24-cv-00140-DCN

Plaintiff, INITIAL REVIEW ORDER BY SCREENING JUDGE v.

IDAHO DEPARTMENT OF CORRECTIONS, CINDY LEE, DW STEPHEN GRILL, CM MONTE HANSON, and ARNS J. LEMONS,

Defendants.

Plaintiff Jason Ryan McDermott, an Idaho Department of Correction (IDOC) inmate housed in an Arizona prison, filed a prisoner civil rights Complaint challenging many aspects of his transfer and out-of-state housing. Dkt. 1. He also filed a “First Amended Complaint” (Dkt. 7) that is intended to supplement the original Complaint, rather than replace it. The Court must review pleadings filed by paupers and prisoners seeking relief against state actors to determine whether summary dismissal is appropriate. See 28 U.S.C. §§ 1915 & 1915A. Having reviewed these pleadings, the Court enters the following Order requiring amendment if Plaintiff desires to proceed. REVIEW OF PLEADINGS 1. Standard of Law for Screening A complaint must contain “a short and plain statement of each claim showing that

the pleader is entitled to relief.” Fed. R. Civ. P. 8(a)(2). The Court liberally construes the pleadings to determine whether a case should be dismissed. Under Rule 8 and 28 U.S.C. §§ 1915 and 1915A, the Court may dismiss some or all of the claims in a complaint for any of the following reasons:  “insufficient facts under a cognizable legal” theory, Robertson v. Dean Witter Reynolds, Inc., 749 F.2d 530, 534 (9th Cir. 1984), meaning that the factual assertions, taken as true, are insufficient for the reviewing court plausibly “to draw the reasonable inference that the defendant is liable for the misconduct alleged,” Ashcroft v. Iqbal, 556 U.S. 662, 678 (2009);  “lack of a cognizable legal theory,” Robertson, 749 F.2d at 534, including that the complaint fails to state a claim upon which relief may be granted, 28 U.S.C. § 1915(e)(2)(B), or the Court applies a procedural bar sua sponte (on its own), see, e.g., Hebrard v. Nofziger, 90 F.4th 1000, 1006 (9th Cir. 2024) (affirming dismissal based on Heck v. Humphrey, 512 U.S. 477 (1994));  frivolousness or maliciousness, 28 U.S.C. § 1915(e)(2)(B); or  seeking monetary relief from a defendant who is immune from such relief, id. To state a claim under 42 U.S.C. § 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). 2. Background of Plaintiff’s Claims

Plaintiff’s claims are as follows:  First Amendment retaliation claims asserting that Idaho officials transferred Plaintiff to an out-of-state prison in retaliation for his exercise of First Amendment rights.  Eighth Amendment claims that the Arizona facility is unsafe.  Eighth Amendment claims that he was ineligible for transfer because of his medical condition of a longstanding traumatic brain injury (TBI).  Eighth Amendment claims that the Arizona facility is not equipped to treat his medical conditions.  Eighth Amendment claim that the conditions during the transportation between Idaho and Arizona were cruel and unusual.  Ex post facto claim related to his transfer to Arizona.  State sovereignty claim that Plaintiff has to answer to conflicting authorities.  State law claim based on IDOC officials failing to follow Idaho law. Plaintiff requests injunctive relief in this case—that the Court compel Idaho prison officials to transfer him back to an Idaho prison. Dkt. 1 at 1, 11. He also requests declaratory relief and desires unspecified “sanctions” against Idaho prison officials. Some of Plaintiff’s claims are direct claims for Idaho officials’ own actions or inactions, and some of them are derivative claims, arising from alleged ongoing constitutional violations occurring in Arizona that are caused by Arizona officials or staff. In Peralta v. Dillard, 744 F.3d 1076 (9th Cir. 2014), the United States Court of Appeals for the Ninth Circuit held that, where injunctive relief is warranted, prison officials must remedy ongoing constitutional violations of which they are aware, regardless of the cause and regardless of whether they had the current resources to provide the remedy. Id. at 1083 (observing that “[l]ack of resources is not a defense to a claim for prospective relief because prison officials may be compelled to expand the pool of existing resources in order to remedy continuing Eighth Amendment violations.”). A pre-requisite to obtaining an

injunction is a finding that Plaintiff’s current conditions of confinement (whether based on Arizona or Idaho officials’ actions or inaction) violate one or more of his constitutional rights and any injunctive relief meets Prison Litigation Reform Act of 1995 (PLRA) limitations: Prospective relief in any civil action with respect to prison conditions shall extend no further than necessary to correct the violation of the Federal right of a particular plaintiff or plaintiffs. The court shall not grant or approve any prospective relief unless the court finds that such relief is narrowly drawn, extends no further than necessary to correct the violation of the Federal right, and is the least intrusive means necessary to correct the violation of the Federal right. The court shall give substantial weight to any adverse impact on public safety or the operation of a criminal justice system caused by the relief.

18 U.S.C.A. § 3626. The type of relief available for each of Plaintiff’s particular claims is a question for another day. 3. First Amendment Retaliation and Statute of Limitations Standards of Law

A First Amendment retaliation claim must allege the following: “(1) An assertion that a state actor took some adverse action against an inmate (2) because of (3) that prisoner’s protected conduct, ... that such action (4) chilled the inmate’s exercise of his First Amendment rights, and (5) the action did not reasonably advance a legitimate correctional goal.” Rhodes v. Robinson, 408 F.3d 559, 567-68 (9th Cir. 2005) (footnote omitted). Although a “chilling effect on First Amendment rights” is enough to state an injury, Gomez v. Vernon, 255 F.3d 1118, 1127 (9th Cir.

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McDermott v. Idaho Department of Corrections, Counsel Stack Legal Research, https://law.counselstack.com/opinion/mcdermott-v-idaho-department-of-corrections-idd-2024.