McKinney v. Gierach

CourtDistrict Court, E.D. Wisconsin
DecidedOctober 18, 2024
Docket2:24-cv-00206
StatusUnknown

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

Bluebook
McKinney v. Gierach, (E.D. Wis. 2024).

Opinion

UNITED STATES DISTRICT COURT EASTERN DISTRICT OF WISCONSIN

WILLIAM MCKINNEY,

Plaintiff,

v. Case No. 24-CV-206

WARDEN MICHAEL GIERACH, GREG GIESE, ANGELA HANSEN, ANGELA WEGNER, and AMANDA BECHARD,

Defendants.

ORDER

Plaintiff William McKinney, who is currently confined at Redgranite Correctional Institution (RCGI) and representing himself, originally filed a petition for a writ of habeas corpus under 28 U.S.C. § 2254. (ECF No. 1.) On June 3, 2024, the court granted McKinney’s motion to reconstrue his petition as a complaint under 42 U.S.C. § 1983, alleging the defendants violated his constitutional rights. (ECF No. 14.) The court has jurisdiction to screen the complaint in light of McKinney’s consent to the full jurisdiction of a magistrate judge and the Wisconsin Department of Justice’s limited consent to the exercise of magistrate judge jurisdiction as set forth in the Memorandum of Understanding between the Wisconsin Department of Justice and this court. SCREENING OF THE COMPLAINT Federal Screening Standard Under the PLRA the court must screen complaints brought by prisoners

seeking relief from a governmental entity or officer or employee of a governmental entity. 28 U.S.C. § 1915A(a). The court must dismiss a complaint if the prisoner raises claims that are legally “frivolous or malicious,” 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. 28 U.S.C. § 1915A(b). In determining whether the complaint states a claim, the court applies the

same standard that applies to dismissals under Federal Rule of Civil Procedure 12(b)(6). See Cesal v. Moats, 851 F.3d 714, 720 (7th Cir. 2017) (citing Booker-El v. Superintendent, Ind. State Prison, 668 F.3d 896, 899 (7th Cir. 2012)). To state a claim a complaint must include “a short and plain statement of the claim showing that the pleader is entitled to relief.” Fed. R. Civ. P. 8(a)(2). The complaint must contain enough facts, accepted as true, to “state a claim for 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)). “A claim has facial plausibility when the plaintiff pleads factual content that allows a court to draw the reasonable inference that the defendant is liable for the misconduct alleged.” Id. (citing Twombly, 550 U.S. at 556). To state a claim for relief under 42 U.S.C. § 1983 a plaintiff must allege that someone deprived him of a right secured by the Constitution or the laws of the

2 United States, and that whoever deprived him of this right was acting under color of state law. D.S. v. E. Morris Cty. Sch. Corp., 799 F.3d 793, 798 (7th Cir. 2015) (citing Buchanan–Moore v. Cty. of Milwaukee, 570 F.3d 824, 827 (7th Cir. 2009)).

The court construes pro se complaints liberally and holds them to a less stringent standard than pleadings drafted by lawyers. Cesal, 851 F.3d at 720 (citing Perez v. Fenoglio, 792 F.3d 768, 776 (7th Cir. 2015)). McKinney’s Allegations McKinney alleges that the defendants failed to give him appropriate due process during his hearing for geriatric early release on November 17, 2021. (ECF

No. 18 at 3.) Specifically, the defendants had made up their minds prior to the hearing not to release McKinney because he did not complete sex-offender training. (Id. at 3-4.) McKinney applied for geriatric release because he is 71 years old and has served over five years of his confinement. (ECF No. 1 at 5.) He notes that he has not received a conduct report since 2010. (Id.) He alleges the only reason he was not granted geriatric release is because he has not completed the required sex-offender

training (SOT-1) program. (Id.) Defendant Amanda Bechard, in her role as program supervisor, failed to get him into the one SOT-1 program RGCI offered before his hearing. (Id. at 4.) McKinney alleges this demonstrates she intentionally wanted to deny him geriatric release. (Id.) Defendant Giese did not conduct all the potential plan reviews, which McKinney states proves he had decided before the hearing to not grant McKinney’s early release. (Id. at 3-4; ECF 18-1 at 3-4.) Defendant Wegner

3 did not take into account McKinney’s low-risk score on the “Compas Risk Assessment,” which McKinney alleges demonstrates she predetermined not to grant early release. (ECF No. 18 at 4.)

McKinney further states that the Program Review Committee misapplied the relevant statute governing geriatric release, Wis. Stat. § 302.113. McKinney asserts that the statute does not require sex-offender programs to be completed before geriatric release could be granted. (ECF No. 1 at 5-7.) Analysis McKinney claims that the defendants violated his Fourteenth Amendment

due process rights when they predetermined to deny him geriatric release on the basis that he failed to complete SOT-1 programing. To allege a due process violation, a plaintiff must show that a state actor deprived him of a protected liberty or property interest without providing adequate process. Salas v. Wisc. Dept. of Corrections, 493 F. 3d 913, 927 (7th Cir. 2007). Liberty interests are “generally limited to freedom from restraint which . . . imposes [an] atypical and significant hardship on the inmate in relation to the ordinary incidents of prison life.” Sandin

v. Conner, 515 U.S. 472, 483-84 (1995). Whether McKinney has a protected interest depends on the content of Wisconsin’s Early Release statute, Wis. Stat. § 302.113, “because an inmate has a liberty interest only if the state’s statutes and regulations create an expectation, rather than a mere hope, of early release.” Frederick v. Frank, 136 Fed. App’x 933, 934 (7th Cir 2005).

4 Section 302.113(9) demonstrates that early release before a mandatory release date is discretionary: “If. . . the program review committee determines that the public interest would be served by a modification of the inmate’s bifurcated

sentence . . . the committee shall approve the petition for referral to the sentencing court.” In short, because McKinney’s early release is at the discretion of the program review committee, he has no protectable liberty interest in his early release. See Winus v. Kemper, Case No. 17-CV-1417, 2017 WL 9485690 at *2 (E.D. Wis. Nov. 13, 2017).

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Related

Sandin v. Conner
515 U.S. 472 (Supreme Court, 1995)
Bell Atlantic Corp. v. Twombly
550 U.S. 544 (Supreme Court, 2007)
Ashcroft v. Iqbal
556 U.S. 662 (Supreme Court, 2009)
Booker-El v. Superintendent, Indiana State Prison
668 F.3d 896 (Seventh Circuit, 2012)
Richard L. Grennier v. Matthew J. Frank
453 F.3d 442 (Seventh Circuit, 2006)
Buchanan-Moore v. County of Milwaukee
570 F.3d 824 (Seventh Circuit, 2009)
Salas v. Wisconsin Department of Corrections
493 F.3d 913 (Seventh Circuit, 2007)
Miguel Perez v. James Fenoglio
792 F.3d 768 (Seventh Circuit, 2015)
D. S. v. East Porter County School Corp
799 F.3d 793 (Seventh Circuit, 2015)
Cesal v. Moats
851 F.3d 714 (Seventh Circuit, 2017)

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Bluebook (online)
McKinney v. Gierach, Counsel Stack Legal Research, https://law.counselstack.com/opinion/mckinney-v-gierach-wied-2024.