Robert Reid v. Brodeur, et al.

2000 DNH 022
CourtDistrict Court, D. New Hampshire
DecidedJanuary 24, 2000
DocketCV-96-492-B
StatusPublished
Cited by1 cases

This text of 2000 DNH 022 (Robert Reid v. Brodeur, et al.) is published on Counsel Stack Legal Research, covering District Court, D. New Hampshire primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

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Robert Reid v. Brodeur, et al., 2000 DNH 022 (D.N.H. 2000).

Opinion

Robert Reid v. Brodeur, et al. CV-96-492-B 01/24/00 UNITED STATES DISTRICT COURT FOR THE DISTRICT OF NEW HAMPSHIRE

Robert Reid

v. Civil N o . 96-492-B Opinion N o . 2000 DNH 022 Paul Brodeur, et al.

MEMORANDUM AND ORDER

Robert Reid has sued 18 present and former members of the

New Hampshire Department of Corrections seeking damages and

injunctive relief pursuant to 42 U.S.C. § 1983. He alleges that

the defendants violated: (1) his Eighth Amendment right to be

free from cruel and unusual punishment; (2) his First Amendment

right to be free from retaliation for exercising his First

Amendment rights; (3) his Fourteenth Amendment right to equal

protection; (4) his Fourteenth Amendment right to procedural due

process; and (5) his First Amendment right of access to the

courts. He has sued all of the defendants in both their

individual and official capacities.

Reid’s core complaint is that several prison guards beat and physically harassed him on several occasions. He asserts that

the beatings and harassment were inflicted to retaliate against

-2- him because he filed unspecified complaints and because he is

black. He also asserts that he was disciplined, reclassified,

placed in solitary confinement, and moved from one section of the

prison to another without justification and without the

procedural safeguards to which he is entitled. Finally, he

claims that prison officials denied him the assistance of a law

clerk and tampered with his legal mail.

Defendants have moved to dismiss the complaint for failure

to state a claim. I briefly address the defendants’ arguments.

I. Official Capacity Claims

Reid’s official capacity claims for damages are barred by

the Eleventh Amendment but his claims for prospective injunctive

relief are not. See Neo Gen Screening, Inc. v . New England

Newborn Screening Program, 187 F.3d 2 4 , 27 (1st C i r . ) , cert.

denied, 120 S . C t . 615 (1999). Accordingly, I dismiss only

Reid’s official capacity claims for damages.

II. Eighth Amendment Claim - Excessive Force

The test for an Eighth Amendment claim alleging the use of

-3- excessive force is whether force was applied “maliciously and

sadistically to cause harm” rather than in a “good faith effort

to maintain or restore discipline.” Hudson v . McMillian, 503

U.S. 1 , 7 (1992). Here, Reid alleges that prison guards

repeatedly physically abused him, not in an effort to maintain

and restore discipline, but to retaliate against him and because

he is black. These allegations state an Eighth Amendment

violation.1 Defendants’ motion to dismiss Reid’s Eighth

Amendment claims is denied.

III. First Amendment - Retaliation Claims

To prevail on a claim of retaliation in violation of his

First Amendment rights, Reid must show that: (1) he had a First

Amendment right; (2) the defendants took an adverse action

against him; (3) with an intention to retaliate; and (4) the

retaliatory act caused the injury for which he is seeking

1 It is unlikely that all of the defendants can be liable for Eighth Amendment violations. Because defendants have not attempted to specify which of them may be held liable and which may not, I will not attempt to sort the matter out on my own. I follow the same approach with respect to Reid’s remaining claims.

-4- compensation. See McDonald v . Steward, 132 F.3d 225, 231 (5th

Cir. 1998). Reid claims that he was beaten, harassed and

suffered other adverse actions because he filed lawsuits against

-5- the prison. This is sufficient to state a claim of unlawful

retaliation. Defendants’ motion to dismiss these claims is

denied.

IV. Fourteenth Amendment

To prove a claim of racial discrimination in violation of

the Fourteenth Amendment’s Equal Protection Clause, Reid must

show that the defendants injured him by intentionally subjecting

him to discrimination without justification because of his race.

See Judge v . City of Lowell, 160 F.3d 6 7 , 75 (1st Cir. 1998).

Here, Reid alleges that he was subject to beatings and other

physical harassment simply because he is black. This is

sufficient to state an equal protection claim. Defendants’

motion to dismiss these claims is denied.

V. Fourteenth Amendment - Procedural Due Process

Reid alleges that he was placed in punitive segregation,

moved from one tier to another within the prison’s special

housing unit, reclassified, and subjected to a loss of good time

credits without the procedures to which he is entitled by state

-6- law and the Fourteenth Amendment’s due process clause.

-7- Defendants first argue that these claims are defective

because Reid has not sufficiently alleged that they have deprived

him of a protected liberty interest. Insofar as Reid argues that

he has a protected liberty interest in avoiding punitive

segregation, movement within the special housing unit, and

reclassification, I agree. See Sandin v . Conner, 512 U.S. 472,

485-86 (1995) (holding hat prisoner’s discipline in segregated

confinement "did not present the type of atypical, significant

deprivation in which a state might conceivably create a liberty

interest”); Harper v . Showers, 174 F.3d 716 (5th Cir. 1999)

(holding that prisoner had no protected property or liberty

interest in custodial classifications). I decline to decide

whether Reid has alleged a liberty interest in the loss of good

time credits as the issue is factually and legally complex, see,

e.g., Gotcher v . Wood, 66 F.3d 1097, 1100 (9th Cir. 1995)

(vacated on other grounds, 520 U.S. 1238 (1997)), and has not

been properly briefed. I also decline to consider whether Reid

must first pursue his claim for loss of good time credits in an

-8- action for habeas corpus, see, e.g., Anyanwutaku v . Moore, 151

F.3d 1053, 1056 (D.C. Cir. 1998).

-9- I dismiss Reid’s procedural due process claims to the extent

that he bases the claim on punitive segregation, transfer within

the special housing unit, or reclassification. I decline to

determine at the present time whether Reid has stated a claim

that he has a protected liberty interest in avoiding the loss of

good time credits and whether he must first pursue this claim

through a habeas corpus petition before bringing a claim for

damages based on 42 U.S.C. § 1983.

Defendants also argue that they are absolutely immune from

liability for any procedural due process violations arising from

the prison disciplinary process. This claim has no merit. See

Cleavinger v . Saxner, 474 U.S. 193, 206 (1985) (recognizing

qualified, but not absolute, immunity for members of prison

disciplinary committee); Hameed v .

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Robert Reid v. Brodeur, et al.
2000 DNH 022 (D. New Hampshire, 2001)

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