PRATHER v. LITHERHAND

CourtDistrict Court, S.D. Indiana
DecidedMarch 24, 2025
Docket2:24-cv-00031
StatusUnknown

This text of PRATHER v. LITHERHAND (PRATHER v. LITHERHAND) 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
PRATHER v. LITHERHAND, (S.D. Ind. 2025).

Opinion

UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF INDIANA TERRE HAUTE DIVISION

REGINALD J. PRATHER, ) ) Plaintiff, ) ) v. ) No. 2:24-cv-00031-JMS-MJD ) R. LITHERHAND, et al., ) ) ) Defendants. )

ORDER SCREENING AND DISMISSING AMENDED COMPLAINT AND DIRECTING ENTRY OF FINAL JUDGMENT

Plaintiff Reginald J. Prather, an Indiana Department of Correction (IDOC) inmate in custody at the Wabash Valley Correctional Facility, filed this civil rights action on January 29, 2024, pursuant to 42 U.S.C. § 1983 based on allegations that Defendants violated his Constitutional rights by seizing his personal mail. Dkt. [1]. On August 2, 2024, the Court screened Mr. Prather's complaint and dismissed his claims as barred by the Indiana statute of limitations. Dkt. [10]. The Court granted Mr. Prather additional time to file his amended complaint no later than October 30, 2024. Dkt. 16. On October 30, 2024, Mr. Prather filed his motion for leave to file amended complaint. Dkt. 17. The clerk is directed to terminate the motion flag at dkt. [17], and the Court proceeds to screen Mr. Prather's amended complaint. I. Screening Standard Because Mr. Prather was a "prisoner" when he filed this action, this Court has an obligation under 28 U.S.C. § 1915A(a) to screen his amended complaint. When screening an amended 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 amended 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 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. Amended Complaint Mr. Prather names three defendants: R. Litherhand, N. Morris, and Nathan Lag. Mr. Prather's factual allegations, summarized here, are accepted as true at the pleading stage. See Lisby v. Henderson, 74 F.4th 470, 472 (7th Cir. 2023). On December 7, 2021, Mr. Prather received a notice of confiscation of books and magazines that had been ordered for him by friends from a company called Special Needs X-press, Inc. Defendants Litherhand and Morris began withholding

Mr. Prather's mail based on false allegations that a K-9 unit had alerted to the presence of drugs on the books and magazines that had been mailed to him. This resulted in his mail being held for weeks at a time. He filed a grievance on December 9, 2021. He received another confiscation slip on December 15, 2021, so he filed another grievance. On December 16, 2021, Mr. Prather submitted another grievance, which was returned on December 21, 2021, because Mr. Prather still had a previous, similar grievance pending. Mr. Prather engaged a friend to order the same books and magazines from the same companies and sent to a different prisoner, who received them without any issues. On December 15, 2021, Defendant Nathan Lag sent Mr. Prather a letter informing him that he was restricted from phone, messaging, and visitation for 30 days. Mr. Prather was singled out for this treatment in retaliation for his grievances. He filed a tort claim but received no compensation. He now seeks compensatory and punitive damages. III. Discussion The complaint is brought pursuant to 42 U.S.C. § 1983. To state a claim under § 1983, a

plaintiff must allege the violation of a right secured by the Constitution or laws of the United States and must show that the alleged deprivation was committed by a person acting under color of state law. L.P. v. Marian Catholic High Sch., 852 F.3d 690, 696 (7th Cir. 2017) (citing West v. Atkins, 487 U.S. 42, 48 (1988)). Suits under § 1983 use the statute of limitations and tolling rules that states employ for personal-injury claims. In Indiana, the applicable statute of limitations period is two years. See Richards v. Mitcheff, 696 F.3d 635, 637 (7th Cir. 2012); Ind. Code § 34–11–2–4. "While state law determines the length of the limitations period, federal law determines the date of accrual of the cause of action. . . . For . . . 1983 purposes, a claim accrues when the plaintiff knows or should know that his or her constitutional rights have been violated. . . . To determine when the claim accrues, a court must first identify the plaintiff's injury and then determine when

the plaintiff could have sued for that injury." Logan v. Wilkins, 644 F.3d 577, 581–82 (7th Cir. 2011) (internal citation omitted). In this case the injury is the confiscation of Mr. Prather's mail, which occurred on December 7 and December 15, 2021, and the 30-day restrictions from December 15, 2021, until January 14, 2022. Mr. Prather does not assert that his mail ever was confiscated after December 15, 2021, or that he received any other retaliation. Although he did not date his original complaint, it was scanned at the Wabash Valley Correctional Facility on January 29, 2024, beyond the expiration of Indiana's 2-year statute of limitations. Although untimeliness is an affirmative defense, a complaint can be dismissed by the Court sua sponte if "the existence of a valid affirmative defense is so plain from the fact 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 (7th Cir. 2013) (stating that when the language of the complaint plainly shows that the statute of limitations bars the suit, dismissal under § 1915A is appropriate); Brownmark Films, LLC v.

Comedy Partners, 682 F.3d 687, 690 (7th Cir. 2012). Mr.

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Related

West v. Atkins
487 U.S. 42 (Supreme Court, 1988)
Bell Atlantic Corp. v. Twombly
550 U.S. 544 (Supreme Court, 2007)
Ashcroft v. Iqbal
556 U.S. 662 (Supreme Court, 2009)
Logan v. Wilkins
644 F.3d 577 (Seventh Circuit, 2011)
Tony Walker v. Tommy G. Thompson
288 F.3d 1005 (Seventh Circuit, 2002)
Brownmark Films, LLC v. Comedy Partners
682 F.3d 687 (Seventh Circuit, 2012)
Dan Richards v. Michael Mitcheff
696 F.3d 635 (Seventh Circuit, 2012)
Matthew Koch v. Katherine Gregory
536 F. App'x 659 (Seventh Circuit, 2013)
Anne O' Boyle v. Real Time Resolutions, Inc.
910 F.3d 338 (Seventh Circuit, 2018)
Daniel Schillinger v. Josh Kiley
954 F.3d 990 (Seventh Circuit, 2020)
Muhammad-Ali v. Final Call, Inc.
832 F.3d 755 (Seventh Circuit, 2016)
Cesal v. Moats
851 F.3d 714 (Seventh Circuit, 2017)
L.P. ex rel. Patterson v. Marian Catholic High School
852 F.3d 690 (Seventh Circuit, 2017)
Ralph Lisby v. Jonathan Henderson
74 F.4th 470 (Seventh Circuit, 2023)

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Bluebook (online)
PRATHER v. LITHERHAND, Counsel Stack Legal Research, https://law.counselstack.com/opinion/prather-v-litherhand-insd-2025.