Randall Morris v. Lauren Howard, et al.

District Court, N.D. Texas·Decided July 15, 2026·No. 3:24-cv-03148·Unknown

Opinion

IN THE UNITED STATES DISTRICT COURT FOR THE NORTHERN DISTRICT OF TEXAS DALLAS DIVISION RANDALL MORRIS, § ID # 15141-010, § Plaintiff, § § v. § No. 3:24-CV-3148-X-BW § LAUREN HOWARD, et al., § Defendants. § Referred to U.S. Magistrate Judge1 FINDINGS, CONCLUSIONS, AND RECOMMENDATION OF THE UNITED STATES MAGISTRATE JUDGE Before the Court is the Verified Complaint (Dkt. No. 3), received on December 13, 2024, and supplemented by the filing received on April 22, 2025. Based on the relevant filings and applicable law, the Court should DISMISS the complaint, as supplemented, under 28 U.S.C. § 1915 and § 1915A. I. INTRODUCTION Randall Morris, a federal prisoner currently incarcerated by the Federal Bureau of Prisons (“BOP”) at the Federal Correctional Institution, Seagoville (“FCI Seagoville”), filed this civil action against Supervisor of Education (“SOE”) Lauren Howard at FCI Seagoville, the warden of FCI Seagoville, and two BOP directors in connection with his conditions of confinement and for constitutional deprivations. (See id. at 1.) His “complaint centers on unreasonable, arbitrary, and extreme restrictions regarding the use of the BOP typewriters and the use of the Inmate

1 By Special Order No. 3-251, this pro se case has been referred to the undersigned magistrate judge for case management. (See Dkt. No. 1.) Trustfund Photocopy Machine.” (Id.) According to Morris, “[t]hese egregious restrictions conflict with the First Amendment as well as specific BOP Program Statements that authorize all inmates to create, duplicate, and share original literary

works[.]” (Id.) He states that he “does not seek a monetary award,” but he seeks injunctive and declaratory relief, costs, attorney’s fees, and “any other appropriate relief.” (Id. at 1, 9.) The Court granted Morris’s subsequent request to supplement his complaint.

(See Dkt. Nos. 10, 13.) Morris supplemented his complaint with additional factual allegations to support his original claims, to support a “reasonable accommodation ADA/RA foundation” stemming from the denial of his accommodation requests for unrestricted access to the typewriters and the copy machine to accommodate physical impairments of his writing hand, and to support a claim of retaliation. (Dkt.

No. 10 at 2 (capitalization altered); see also id. at 2-6.) II. PRELIMINARY SCREENING Morris is a federal prisoner who has been permitted to proceed in forma pauperis (“IFP”) in this action. (See Dkt. No. 6.) As a prisoner seeking redress from officers of a governmental entity, his complaint is subject to preliminary screening under 28 U.S.C. § 1915A. See Martin v. Scott, 156 F.3d 578, 579-80 (5th Cir. 1998).

Because Morris is proceeding IFP, the complaint also is subject to screening under § 1915(e)(2). Both § 1915A(b) and § 1915(e)(2)(B) provide for sua sponte dismissal of a complaint, or any part of it, if the Court finds it 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. A frivolous complaint lacks any arguable basis, either in fact or in law, for the

wrong alleged. Neitzke v. Williams, 490 U.S. 319, 325 (1989). A complaint has no arguable basis in fact if it rests upon clearly fanciful or baseless factual contentions, and similarly lacks an arguable basis in law if it embraces indisputably meritless legal theories. See id. at 327; Geiger v. Jowers, 404 F.3d 371, 373 (5th Cir. 2005). When analyzing a prisoner’s complaint, the court may consider reliable evidence such as

the plaintiff’s allegations, responses to a questionnaire, and authenticated prison records. See Wilson v. Barrientos, 926 F.2d 480, 483-84 (5th Cir. 1991). In evaluating the sufficiency of a complaint, the Court accepts well-pleaded factual allegations as true, but it does not credit conclusory allegations or assertions

that merely restate the legal elements of a claim. Chhim v. Univ. of Tex. at Austin, 836 F.3d 467, 469 (5th Cir. 2016). While courts hold pro se plaintiffs to a more lenient standard when analyzing complaints, such plaintiffs must nevertheless plead factual allegations that raise the right to relief above a speculative level. Id. (citing Taylor v. Books A Million, Inc., 296 F.3d 376, 378 (5th Cir. 2002)).

III. ANALYSIS Because Morris seeks relief in this action from federal officers for violation of his constitutional rights, his claims are fairly interpreted as arising under Bivens v. Six Unknown Named Agents of Fed. Bureau of Narcotics, 403 U.S. 388, 397 (1971). See Montgomery v. Deitelbaum, No. 3:09-CV-2407-M-BH, 2010 WL 582146, at *2 (N.D. Tex. Feb. 18, 2010). In the supplement to his complaint, Morris also implicates claims under the Americans with Disabilities Act of 1990, as amended (“ADA”), and the Rehabilitation Act of 1973 (“RA”). (See Dkt. No. 10 at 2-4.) Morris does

not specify in either his complaint or his supplement whether he is suing Defendants in their official or individual capacities. The Court therefore will address the claims against Defendants in both their official and individual capacities. A. Bivens

Morris alleges that various policies and restrictions imposed at FCI Seagoville by SOE Howard regarding inmate usage of the BOP typewriters and photocopier violate his First Amendment rights and BOP regulations and Program Statements § 1315.07 and § 5350.27. (See Dkt. No. 3 at 1-4, 29-36.) He also appears to allege that SOE Howard has retaliated against him because of personal resentment, literary

works Morris has published, his use of the BOP’s administrative grievance process, and his filing of this action. (See id. at 7; Dkt. No. 10 at 4-5.) Morris states that the other three Defendants—FCI Seagoville’s warden, the BOP South Central Regional Director, and the BOP Central Office Director—successively have “superior authority over the actions of subordinates,” and as such could have granted his

requests for “general inmate use of the typewriters and the Inmate Trustfund Photocopy Machine.” (Dkt. No. 3 at 6-7.) Assuming for purposes of this recommendation that Morris seeks relief in this action that is available under Bivens in the first instance, the Court must determine if his claims against Defendants properly arise under Bivens. See Evans v. Ball, 168 F.3d 856, 863 n.10 (5th Cir. 1999) (“A Bivens action is analogous to an action under § 1983—the only difference being that § 1983 applies to constitutional violations by state, rather than federal, officials.”), abrogated on other grounds by Castellano v. Fragozo,

352 F.3d 939, 948-49 (5th Cir. 2003). 1. Official Capacity Claims against federal employees in their official capacities are merely another way of pleading an action against the entity or agency of which the individual

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Randall Morris v. Lauren Howard, et al., (N.D. Tex. 2026).

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