SETH WATSON v. CAROL MICI & Others.

CourtMassachusetts Appeals Court
DecidedMay 17, 2024
Docket23-P-0321
StatusUnpublished

This text of SETH WATSON v. CAROL MICI & Others. (SETH WATSON v. CAROL MICI & Others.) is published on Counsel Stack Legal Research, covering Massachusetts Appeals Court primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
SETH WATSON v. CAROL MICI & Others., (Mass. Ct. App. 2024).

Opinion

NOTICE: Summary decisions issued by the Appeals Court pursuant to M.A.C. Rule 23.0, as appearing in 97 Mass. App. Ct. 1017 (2020) (formerly known as rule 1:28, as amended by 73 Mass. App. Ct. 1001 [2009]), are primarily directed to the parties and, therefore, may not fully address the facts of the case or the panel's decisional rationale. Moreover, such decisions are not circulated to the entire court and, therefore, represent only the views of the panel that decided the case. A summary decision pursuant to rule 23.0 or rule 1:28 issued after February 25, 2008, may be cited for its persuasive value but, because of the limitations noted above, not as binding precedent. See Chace v. Curran, 71 Mass. App. Ct. 258, 260 n.4 (2008).

COMMONWEALTH OF MASSACHUSETTS

APPEALS COURT

23-P-321

SETH WATSON

vs.

CAROL MICI1 & others.2

MEMORANDUM AND ORDER PURSUANT TO RULE 23.0

The plaintiff, Seth Watson, filed a complaint in Superior

Court seeking a declaration that the North Central Correctional

Institution (NCCI) library services policy relating to the

photocopying of legal documents by inmates and part of the

corresponding Department of Correction (DOC) regulation are

unconstitutional and an injunction against enforcement of the

NCCI policy. See 103 Code Mass. Regs. § 478 (2017). Watson

also sought compensatory and punitive damages against the

defendants for alleged violations of his constitutional rights

1 Individually and as Commissioner of Correction.

2Department of Correction; Matthew Divris, individually and in his capacity as superintendent of North Central Correctional Institution, Gardner; and Carolyn Murray, individually and in her capacity as librarian at North Central Correctional Institution, Gardner. under G. L. c. 12, §§ 11H and 11I. The court sua sponte

dismissed the complaint against DOC for failure to complete

service. See Superior Court Standing Order 1-88 (2020). A

judge of the Superior Court subsequently allowed the remaining

defendants' motion to dismiss the complaint and Watson appealed.

We affirm.

Background. We recite the pertinent facts alleged in

Watson's complaint. Watson is incarcerated at NCCI. He has a

disability that interferes with his daily functions and causes

him severe pain when he types or sits for long periods of time.

In 2021, Watson's two minor children stopped visiting him at

NCCI. In May 2021, in response to his request, the Probate and

Family Court sent Watson a form to petition for visitation.

Watson was instructed to send copies of the petition to his

children's mother and her attorney. Citing the applicable

regulations, NCCI librarian Carolyn Murray denied Watson's

request to make two photocopies of the petition. She told him

that, notwithstanding his disability, he could type copies using

a typewriter. Due to his limited access to the library during

the COVID-19 pandemic and the pain associated with his

disability, Watson spent about a month typing the two copies,

thus delaying his petition for visitation. When Watson later

requested to photocopy his response to the opposition to his

petition, Murray again denied his request for two photocopies.

2 Four days later, Watson finished typing the copies and mailed

them.

Discussion. 1. Request for declaratory and injunctive

relief. "We review the denial of a motion to dismiss de novo."

Drake v. Leicester, 484 Mass. 198, 199 (2020). "[T]he

fundamental constitutional right of access to the courts

requires prison authorities to assist inmates in the preparation

and filing of meaningful legal papers by providing prisoners

with adequate law libraries . . . ." Lewis v. Casey, 518 U.S.

343, 346 (1996), quoting Bounds v. Smith, 430 U.S. 817, 828

(1977). Because Watson alleged that the defendants interfered

with his constitutional right of access to the courts, he had a

private right of action under 42 U.S.C. § 1983.

Watson alleges that the defendants denied his access to the

courts by refusing to provide photocopies of his legal

documents. At the time, NCCI's procedure stated that

photocopying services were available to inmates "for the purpose

of reproducing original legal documents . . . in support of

[c]riminal litigation challenging the inmate's sentence . . . or

in support of civil litigation challenging the conditions of

[his] confinement." Cf. 103 Code Mass. Regs. § 478.05 (2017).

In July 2022, the photocopying procedure expanded to include

"[o]ther original legal documents upon showing of legal need."

Because Watson seeks declaratory and injunctive relief with

3 respect to a policy that is no longer in effect, his request for

equitable relief is moot. See Lynn v. Murrell, 489 Mass. 579,

582 (2022) ("A party no longer has a personal stake in a case

where a court can order no further effective relief" [quotations

and citation omitted]). Watson also asserts that the issue is

ripe for review because, even though the revised policy broadens

the category of legal documents for which photocopying services

are available, the corresponding DOC regulation was not

similarly amended. However, Watson does not contend that he

will imminently suffer an injury under the revised policy, thus

his claim is not yet ripe for review. See Department of

Community Affairs v. Massachusetts State College Bldg. Auth.,

378 Mass. 418, 422 (1979) (power to render declaratory and other

relief limited to cases where actual controversy has arisen).

Even if we reached Watson's challenge to NCCI's prior

policy, his argument would fail for multiple reasons. In

particular, Watson ultimately was able to use NCCI library

services to file his legal documents, albeit after some delay.

Slower access to the courts is not the same as denial of access

to the courts and does not constitute a substantial injury. See

Casey, 518 U.S. at 351-352 (injury suffered by inmate must be

substantial, such as dismissal of action or inability to file

complaint). Watson's challenge to the DOC regulation fails for

the same reason.

4 2. Request for damages. Watson also sought damages

against the defendants under G. L. c. 12, §§ 11H and 11I. The

defendants assert that they have qualified immunity. To

determine whether a defendant is entitled to a defense of

qualified immunity, we consider

"(1) whether the facts taken in the light most favorable to the plaintiff demonstrate that there was a violation of the plaintiff's Federal constitutional or statutory rights; (2) if so, whether at the time of the violation those rights were clearly established; and (3) whether a reasonable person in the defendant's position would understand that his conduct violated those clearly established rights" (footnote omitted).

Cristo v. Evangelidis, 90 Mass. App. Ct. 585, 590 (2016). As

discussed above, the defendants did not violate Watson's

constitutional right to access the courts because he was able to

file his legal documents. Even if Watson had alleged facts

suggesting that the defendants' conduct infringed on his right

to access the courts, however, any right to photocopies of the

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Related

Bounds v. Smith
430 U.S. 817 (Supreme Court, 1977)
Lewis v. Casey
518 U.S. 343 (Supreme Court, 1996)
Cristo v. Evangelidis
62 N.E.3d 94 (Massachusetts Appeals Court, 2016)
Department of Community Affairs v. Massachusetts State College Building Authority
392 N.E.2d 1006 (Massachusetts Supreme Judicial Court, 1979)
Longval v. Commissioner of Correction
448 Mass. 412 (Massachusetts Supreme Judicial Court, 2007)
Iannacchino v. Ford Motor Co.
451 Mass. 623 (Massachusetts Supreme Judicial Court, 2008)
Chace v. Curran
881 N.E.2d 792 (Massachusetts Appeals Court, 2008)

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