Robert Antonio Clayton v. Sgt. Krystal Spencer, Cpl. Kiene

CourtDistrict Court, D. South Carolina
DecidedOctober 17, 2025
Docket9:25-cv-06147
StatusUnknown

This text of Robert Antonio Clayton v. Sgt. Krystal Spencer, Cpl. Kiene (Robert Antonio Clayton v. Sgt. Krystal Spencer, Cpl. Kiene) is published on Counsel Stack Legal Research, covering District Court, D. South Carolina primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Robert Antonio Clayton v. Sgt. Krystal Spencer, Cpl. Kiene, (D.S.C. 2025).

Opinion

UNITED STATES DISTRICT COURT DISTRICT OF SOUTH CAROLINA

Robert Antonio Clayton, ) C/A No. 9:25-cv-06147-RMG-MHC ) Plaintiff, ) ) v. ) REPORT AND RECOMMENDATION ) Sgt. Krystal Spencer, Cpl. Kiene, ) ) Defendants. ) )

This is a civil action filed by Plaintiff Robert Antonio Clayton, a pretrial detainee proceeding pro se. Under 28 U.S.C. § 636(b) and Local Civil Rule 73.02(B)(2) (D.S.C.), pretrial proceedings in this action have been referred to the assigned United States Magistrate Judge. In an Order dated September 8, 2025, Plaintiff was directed to bring his case into proper form by providing the specified documents. Plaintiff was also notified of pleading deficiencies and given the opportunity to amend his Complaint. See ECF No. 5. The time for Plaintiff to bring his case into proper form has passed, Plaintiff has failed to bring his case into proper form, and he has not filed an amended complaint. I. BACKGROUND Plaintiff is a pretrial detainee at the Greenville County Detention Center (GCDC). He appears to allege that Defendants violated prison policy by covering the window to his cell with a steel door. Plaintiff claims he experienced mental depression and other mental health symptoms. He also claims he developed a “rocking” habit. ECF No. 1 at 6-8. Plaintiff requests injunctive and monetary relief. Id. at 8. II. STANDARD OF REVIEW

A pro se Complaint is reviewed pursuant to the procedural provisions of 28 U.S.C. § 1915, the Prison Litigation Reform Act, Pub. L. No. 104–134, 110 Stat. 1321 (1996), and in light of the following precedents: Denton v. Hernandez, 504 U.S. 25 (1992), Neitzke v. Williams, 490 U.S. 319 (1989), Haines v. Kerner, 404 U.S. 519 (1972), and Todd v. Baskerville, 712 F.2d 70 (4th Cir. 1983). Pro se complaints are held to a less stringent standard than those drafted by attorneys, and a court is charged with liberally construing a complaint filed by a pro se litigant to allow the development of a potentially meritorious case. See Erickson v. Pardus, 551 U.S. 89, 94 (2007); King v. Rubenstein, 825 F.3d 206, 214 (4th Cir. 2016). However, the requirement of liberal construction does not mean that this Court can ignore a clear failure in the pleading to allege facts which set forth a claim currently cognizable in a federal district court. See Weller v. Dep’t of Soc.

Servs., 901 F.2d 387 (4th Cir. 1990); see also Ashcroft v. Iqbal, 556 U.S. 662, 684 (2009) (outlining pleading requirements under Rule 8 of the Federal Rules of Civil Procedure for “all civil actions”). III. DISCUSSION It is recommended that this action be summarily dismissed for the reasons discussed below. A. Lack of Jurisdiction This action is subject to summary dismissal for lack of federal court jurisdiction. Federal courts are courts of limited jurisdiction, see Kokkonen v. Guardian Life Ins. Co. of America, 511 U.S. 375, 377 (1994), and a district court is charged with ensuring that all cases before it are properly subject to such jurisdiction. In re Bulldog Trucking, Inc., 147 F.3d 347, 352 (4th Cir. 1998). The Complaint filed in this case is subject to summary dismissal without service of process

because it fails to state a claim which this Court may consider under its federal question jurisdiction, see 28 U.S.C. § 1331, or its diversity jurisdiction, see 28 U.S.C. § 1332.1 Plaintiff

appears to be attempting to assert federal question jurisdiction pursuant to 42 U.S.C. § 1983, which “‘is not itself a source of substantive rights,’ but merely provides ‘a method for vindicating federal rights elsewhere conferred.’” Albright v. Oliver, 510 U.S. 266, 271 (1994) (quoting Baker v. McCollan, 443 U.S. 137, 144 n. 3 (1979)). A civil action under § 1983 “creates a private right of action to vindicate violations of ‘rights, privileges, or immunities secured by the Constitution and laws’ of the United States,” Rehberg v. Paulk, 566 U.S. 356, 361 (2012). To state a claim under § 1983, a plaintiff must allege two essential elements: (1) that a right secured by the Constitution or laws of the United States was violated, and (2) that the alleged violation was committed by a person acting under the color of state law. West v. Atkins, 487 U.S. 42, 48 (1988). In response to the question on the Complaint form asking Plaintiff what federal

constitutional or statutory right he claims is being violated, he failed to list any federal constitutional or statutory right. See ECF No. 1 at 4. Instead, Plaintiff appears to allege that Defendants violated GCDC policies by allowing his cell window to be covered. Such allegations are not actionable in a § 1983 action as a violation of GCDC policies and/or procedures does not constitute a violation of Plaintiff’s constitutional rights. See Keeler v. Pea, 782 F. Supp. 42, 44 (D.S.C. 1992); cf. Johnson v. S.C. Dep’t of Corrs., No. 06B2062, 2007 WL 904826 at *12 (D.S.C. Mar. 21, 2007) (A plaintiff’s allegation that defendants did not follow their own policies or

1 A district court may also have jurisdiction of a civil action “where the matter in controversy exceeds the sum or value of $75,000...and is between – (1) citizens of different States...”. 28 U.S.C. § 1332. However, Plaintiff has not asserted diversity jurisdiction and has not alleged complete diversity of the parties. See Owen Equipment & Erection Co. v. Kroger, 437 U.S. 365, 372-374 (1978) (Complete diversity of parties means that no party on one side may be a citizen of the same State as any party on the other side). Here, there is not complete diversity because Plaintiff and Defendants all appear to be citizens of South Carolina. See ECF No. 1 at 2-3. procedures, standing alone, does not amount to a constitutional violation.) (citing Riccio v. County

of Fairfax, Virginia, 907 F.2d 1459, 1469 (4th Cir. 1990)) (if state law grants more procedural rights than the Constitution requires, a state’s failure to abide by that law is not a federal due process issue). B. Failure to Bring Case Into Proper Form As noted above, Plaintiff has also failed to bring this case into proper form.

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Related

Link v. Wabash Railroad
370 U.S. 626 (Supreme Court, 1962)
Haines v. Kerner
404 U.S. 519 (Supreme Court, 1972)
Owen Equipment & Erection Co. v. Kroger
437 U.S. 365 (Supreme Court, 1978)
Baker v. McCollan
443 U.S. 137 (Supreme Court, 1979)
Thomas v. Arn
474 U.S. 140 (Supreme Court, 1986)
West v. Atkins
487 U.S. 42 (Supreme Court, 1988)
Neitzke v. Williams
490 U.S. 319 (Supreme Court, 1989)
Denton v. Hernandez
504 U.S. 25 (Supreme Court, 1992)
Albright v. Oliver
510 U.S. 266 (Supreme Court, 1994)
Kokkonen v. Guardian Life Insurance Co. of America
511 U.S. 375 (Supreme Court, 1994)
Erickson v. Pardus
551 U.S. 89 (Supreme Court, 2007)
Ashcroft v. Iqbal
556 U.S. 662 (Supreme Court, 2009)
United States v. Edward Lester Schronce, Jr.
727 F.2d 91 (Fourth Circuit, 1984)
Ballard v. Carlson
882 F.2d 93 (Fourth Circuit, 1989)
Rehberg v. Paulk
132 S. Ct. 1497 (Supreme Court, 2012)
In Re Bulldog Trucking, Incorporated
147 F.3d 347 (Fourth Circuit, 1998)
Keeler v. Pea
782 F. Supp. 42 (D. South Carolina, 1992)

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Robert Antonio Clayton v. Sgt. Krystal Spencer, Cpl. Kiene, Counsel Stack Legal Research, https://law.counselstack.com/opinion/robert-antonio-clayton-v-sgt-krystal-spencer-cpl-kiene-scd-2025.