Ramel Theodore Troy v. Jack Hendrix, et al.

CourtDistrict Court, N.D. Indiana
DecidedMay 20, 2026
Docket3:24-cv-00605
StatusUnknown

This text of Ramel Theodore Troy v. Jack Hendrix, et al. (Ramel Theodore Troy v. Jack Hendrix, et al.) is published on Counsel Stack Legal Research, covering District Court, N.D. Indiana primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Ramel Theodore Troy v. Jack Hendrix, et al., (N.D. Ind. 2026).

Opinion

UNITED STATES DISTRICT COURT NORTHERN DISTRICT OF INDIANA SOUTH BEND DIVISION

RAMEL THEODORE TROY,

Plaintiff,

v. CAUSE NO. 3:24-CV-605-PPS-APR

JACK HENDRIX, et al.,

Defendants.

OPINION AND ORDER Ramel Theodore Troy, a prisoner without a lawyer, filed an amended complaint against nine defendants. Troy alleges the defendants placed him on department-wide restrictive housing status for about four years while he was housed at Westville Control Unit, denied him a meaningful review of this placement, and subjected him to certain conditions of confinement, in violation of his Fourteenth and Eighth Amendment rights. He also asserts he was prevented from exercising his religion, sending and receiving mail, and accessing the courts in violation of the First Amendment. Troy further contends that his Fourteenth Amendment equal protection rights were violated when he was treated less favorably than inmates in disciplinary segregation and he was denied access to the grievance process. “A document filed pro se is to be liberally construed, and a pro se complaint, however inartfully pleaded, must be held to less stringent standards than formal pleadings drafted by lawyers.” Erickson v. Pardus, 551 U.S. 89, 94 (2007) (quotation marks and citations omitted). Nevertheless, under 28 U.S.C. § 1915A, I must review the merits of a prisoner’s complaint and dismiss it if the action is frivolous or malicious, fails to state a claim upon which relief may be granted, or seeks monetary relief against

a defendant who is immune from such relief. Background In his amended complaint1, Troy states he was housed in restrictive housing units in two different states from August 2015 to January 2024. ECF 6 at 1, 20. He was initially housed at a facility in North Carolina, where he was placed in disciplinary segregation for sixty days for possessing a homemade knife. Id. at 20. After he

completed his disciplinary time, Troy was reclassified and placed in administrative segregation in North Carolina until February 26, 2020, when an out-of-state compact contract was granted, allowing Troy to be transferred to an Indiana Department of Correction facility. Id. Troy believed that, once he was transferred, he would be placed in general population. Id. He was subsequently transferred to Westville Control Unit

(“WCU”), but instead of being placed in general population, he was placed on department-wide restricted housing.2 Id. at 7, 20. He remained at WCU until January 24,

1 Admittedly, this Court has taken a long time to screen this complaint, and generally speaking parties have a right to expect better. But Troy’s amended complaint is 46 pages in length, disorganized, and difficult to understand. He scatters facts and defendants throughout the 46-page complaint expecting the court to piece them together to determine if he may proceed on any claims. This resulted in a time- consuming review process. 2 Restrictive housing (i.e., segregation) is used for disciplinary purposes when segregation time is imposed after a hearing on a conduct report, or it can be used administratively, as a “form of housing for offenders whose continued presence in the general population would pose a serious threat to life, property, self, staff, or other offenders, or to the security or orderly operation of a facility.” Ind. Dep’t of Corr. Policy & Admin. Proc., Administrative Restrictive Status Housing, No. 02-01-111 (eff. Oct. 1, 2021), at p.2, available at https://www.in.gov/idoc/files/policy-and-procedure/policies/02-01-111-ARSH-10-1- 2021.pdf (last visited May 13, 2026). Department-wide administrative restrictive status housing, as opposed to a unit within a facility designated as restricted housing, is designed to house “offenders at a facility who have a history of battery on others or who, in the opinion of Department or facility staff, present an extraordinary threat to themselves or others or who present special safety and security concerns (e.g., seriously injuring staff or offenders, participating in a hostage situation, identified as a 2024. Id. at 20. After that, he was transferred to Wabash Valley Correctional Facility where he is currently housed. See ECF 5.

Troy is suing about events that occurred while he was housed at WCU from February 2020 to January 2024. ECF 6 at 20. He asserts his placement in WCU’s restrictive housing was improper because his placement was based on past conduct and amounted to continued punishment for conduct violations that occurred at a North Carolina Department of Corrections facility. Id. at 10, 28. Troy represents he has not had a major disciplinary infraction in over six years, yet he was not released from WCU

“due to his conduct history in North Carolina.” Id. at 21. He explains that the criteria used for placement in WCU’s restrictive housing was vague, subjective, and inadequate to protect his liberty interests. This enabled the defendants to house him indefinitely in WCU. Id. at 13. Troy contends the defendants sanctioned his placement in WCU without any meaningful review or a hearing and told him placement in WCU was

appropriate due to “safety and security” concerns. Id. at 9, 21. In other words, Troy claims the defendants used department-wide restrictive housing status as a pretext for punishing him. Id. at 28. Troy asserts he was subjected to conditions that amounted to an atypical and significant hardship such that he was entitled to due process, and the process he received at WCU was inadequate. Id. at 29. He seeks monetary damages and

a permanent injunction for the alleged violations. Id. at 43-45. But his request for a permanent injunction is moot because he is currently housed at Wabash Valley

security threat group leader, heavily involved in trafficking or having a lengthy history of serious [Class A and/or Class B] disciplinary code violations).” Id. at 4. The policy mandates periodic review of an administrative placement. See id. at pp.14-15. Correctional Facility (not WCU) and there is no indication that he will be returned to WCU anytime soon. See ECF 5. Fourteenth Amendment Due Process

The Fourteenth Amendment provides state officials shall not “deprive any person of life, liberty, or property, without due process of law . . ..” U.S. Const. amend. XIV, § 1. The Constitution does not create a due process liberty interest in avoiding transfer within a correctional facility or remaining in the general prison population. See Wilkinson v. Austin, 545 U.S. 209, 222 (2005); Sandin v. Conner, 515 U.S. 472, 484 (1995).

Instead, an inmate will be entitled to due process protections only when the more restrictive conditions pose an “atypical and significant hardship on the inmate in relation to the ordinary incidents of prison life.” Sandin, 515 U.S. at 484-85. After Sandin, inmates have no liberty interest in avoiding short-term transfer to segregation for administrative, protective, or investigative purposes, even when they are subjected to

harsher conditions as a result. See, e.g., Townsend v. Fuchs, 522 F.3d 765, 766 (7th Cir. 2008); Lekas v. Briley, 405 F.3d 602, 608-09 (7th Cir. 2005). But placement in long-term segregation (approaching a year or more) is a different kettle of fish. It can implicate a liberty interest, requiring further inquiry into whether the conditions of confinement impose an atypical, significant hardship. See

Marion v.

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