Michael Ray Thomas v. Dullock, et al.

CourtDistrict Court, E.D. Michigan
DecidedJanuary 22, 2026
Docket2:25-cv-12758
StatusUnknown

This text of Michael Ray Thomas v. Dullock, et al. (Michael Ray Thomas v. Dullock, et al.) is published on Counsel Stack Legal Research, covering District Court, E.D. Michigan primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Michael Ray Thomas v. Dullock, et al., (E.D. Mich. 2026).

Opinion

UNITED STATES DISTRICT COURT EASTERN DISTRICT OF MICHIGAN SOUTHERN DIVISION

MICHAEL RAY THOMAS,

Plaintiff,

v. Case No. 25-cv-12758 HON. MARK A. GOLDSMITH DULLOCK, et al.,

Defendants. ______________________________/

OPINION AND ORDER OF PARTIAL SUMMARY DISMISSAL

This is a pro se prisoner civil rights case filed under 42 U.S.C. § 1983. Michigan prisoner Michael Ray Thomas filed a complaint against Michigan Department of Corrections (MDOC) employees Mailroom Employee Dullock, Prison Counselor Trine, Warden Floyd, Grievance Coordinator Flynn, Unknown Warner, and Deputy Director Jeremy Bush. Compl. (Dkt. 1). The Court has reviewed the complaint and concludes that it will be dismissed, in part, for failing to state a legally cognizable claim pursuant to the screening standards under 28 U.S.C. § 1915A. I. BACKGROUND The incidents giving rise to Thomas’s claims occurred during his incarceration at the Cooper Street Correctional Facility in Jackson, Michigan. On April 15, 2025, Thomas’s mother mailed him four books from an MDOC approved vendor, Barnes and Noble: How to Invest in the Stock Market, How to Make Money in Stocks, Investing for Beginners, and Mutual Funds Investing for Beginners. Compl. at PageID.5. On April 22, 2025, Thomas received a Notice of Package/Mail Rejection indicating that all four books were rejected by Defendant Dullock. Id. Thomas states that the books were rejected under the prison policy that “prisoners are prohibited from receiving mail that may pose a threat to the security, good order, or discipline of the facility; facilitate or encourage criminal activity or interfere with the rehabilitation of the prisoner.” Id. at PageID.6. The notice also stated that the mail was prohibited for the purpose of operating a business enterprise while in the facility. Id. After reviewing the notice, Thomas requested a hearing. Id. Thomas challenged the rejection of the books, arguing that he was presently earning a degree in business administration

and sought to open a business upon his release from prison. Id. at PageID.7. The hearing report concluded that the books were prohibited because “[P]risoner shall not be permitted to purchase or order goods or services on a credit or cash-on delivery (i.e., C.O.D.) basis. Prisoner shall not possess accounts at financial institutions or use credit cards.” Id. at PageID.8. Thomas appealed the hearing report and filed various grievances on the issue. In his complaint, Thomas states that Defendants violated his First Amendment rights because the rejected mail does not violate any MDOC policies. He sues Defendants in their individual and official capacities. He seeks monetary and injunctive-type relief. II. LEGAL STANDARD

Thomas is proceeding without prepayment of the fees and costs in this action. Under the Prison Litigation Reform Act of 1996 (PLRA), the Court is required to sua sponte dismiss an in forma pauperis complaint before service on a defendant if it determines that the action is frivolous or malicious, fails to state a claim upon which relief can be granted, or seeks monetary relief against a defendant who is immune from such relief. See 42 U.S.C. § 1997e(c); 28 U.S.C. § 1915(e)(2)(B). The Court is similarly required to dismiss a complaint seeking redress against government entities, officers, and employees which it finds to be frivolous or malicious, fails to state a claim upon which relief may be granted, or seeks monetary relief from a defendant who is immune from such relief. See 28 U.S.C. § 1915A. A complaint is frivolous if it lacks an arguable basis in law or in fact. Denton v. Hernandez, 504 U.S. 25, 31 (1992). A pro se civil rights complaint is to be construed liberally. Haines v. Kerner, 404 U.S. 519, 520–521 (1972). Nonetheless, Federal Rule of Civil Procedure 8(a) requires that a complaint set forth “a short and plain statement of the claim showing that the pleader is entitled to relief,” as well as “a demand for the relief sought.” Fed. R. Civ. P. 8(a)(2), (3). The purpose of this rule is

to “give the defendant fair notice of what the claim is and the grounds upon which it rests.” Bell Atlantic Corp. v. Twombly, 550 U.S. 544, 555 (2007) (punctuation modified). While this notice pleading standard does not require “detailed” factual allegations, it does require more than the bare assertion of legal principles or conclusions. Id. at 555. Rule 8 “demands more than an unadorned, the defendant-unlawfully-harmed me accusation.” Ashcroft v. Iqbal, 556 U.S. 662, 678 (2009). “A pleading that offers labels and conclusions or a formulaic recitation of the elements of a cause of action will not do.” Id. (punctuation modified). “Nor does a complaint suffice if it tenders naked assertions devoid of further factual enhancement.” Id. (punctuation modified). “Factual allegations must be enough to raise a right to relief above the speculative level on the assumption

that all the allegations in the complaint are true (even if doubtful in fact).” Twombly, 550 U.S. at 555 (punctuation modified). To state a civil rights claim under 42 U.S.C. § 1983, a plaintiff must allege that: (i) he or she was deprived of a right, privilege, or immunity secured by the federal Constitution or laws of the United States; and (ii) the deprivation was caused by a person acting under color of state law. Flagg Bros. v. Brooks, 436 U.S. 149, 155–157 (1978). The plaintiff must establish the liability of each individual defendant by that person’s own conduct. “Because vicarious liability is inapplicable to . . . § 1983 suits, a plaintiff must plead that each Government-official defendant, through the official’s own individual actions, has violated the Constitution.” Iqbal, 556 U.S. at 676 (punctuation modified). III. DISCUSSION A. Denial of Grievances The Court construes Thomas’s complaint to assert constitutional claims regarding the denial and/or rejection of his grievances against Defendants Flynn and Warner. After the appeal,

Thomas filed a Step I grievance, which was rejected by Defendant Flynn. Thomas’s Step II grievance was denied by Warden Floyd. Defendant Warner denied the Step III grievance appeal. To the extent Thomas challenges the grievance process, he has no due process right to file a prison grievance. The courts repeatedly have held that there exists no constitutionally protected due process right to an effective prison grievance procedure. See Hewitt v. Helms, 459 U.S. 460, 467 (1983); Walker v. Mich. Dep’t of Corr., 128 F. App’x 441, 445 (6th Cir. 2005); Argue v. Hofmeyer, 80 F. App’x 427, 430 (6th Cir. 2003); Young v. Gundy, 30 F. App’x 568, 569–570 (6th Cir. 2002); Carpenter v. Wilkinson, No.

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Michael Ray Thomas v. Dullock, et al., Counsel Stack Legal Research, https://law.counselstack.com/opinion/michael-ray-thomas-v-dullock-et-al-mied-2026.