Shields v. Mississippi Department of Corrections

CourtDistrict Court, S.D. Mississippi
DecidedAugust 6, 2025
Docket3:23-cv-00516
StatusUnknown

This text of Shields v. Mississippi Department of Corrections (Shields v. Mississippi Department of Corrections) is published on Counsel Stack Legal Research, covering District Court, S.D. Mississippi primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Shields v. Mississippi Department of Corrections, (S.D. Miss. 2025).

Opinion

UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF MISSISSIPPI NORTHERN DIVISION

MARY SUE SHIELDS PLAINTIFF

V. CIVIL ACTION NO. 3:23-CV-516-DPJ-ASH

MISSISSIPPI DEPARTMENT OF CORRECTIONS, et al DEFENDANTS

ORDER

Pro se Plaintiff Mary Sue Shields, an inmate currently housed at Delta Correctional Facility (DCF) in Greenwood, Mississippi, sued Mississippi Department of Corrections, Major Ramona Matthews-Ellis, Commissioner Burl Cain, Deputy Commissioner McDonald, and Deputy Commissioner Mallett under 42 U.S.C. § 1983. Plaintiff is proceeding in forma pauperis (IFP). See Order [12]. The Court, having liberally construed Plaintiff’s Complaint [1], Amended Complaint [8], and Responses [18, 19], finds that certain claims should be dismissed; Shields will be given a final opportunity to allege facts supporting one claim. I. Background A. Procedural History Shields filed this lawsuit on August 9, 2023. Compl. [1]. Because she did not pay the filing fee, the Court prompted her to do so or file an application to proceed in forma pauperis. Order [4]. Shields responded by filing an IFP application [7] and a motion to amend [8], which the Court construed as an Amended Complaint. Order [14] (granting motion to amend). Needing additional information about her claims, the Court ordered Shields to file a response, Order [15], and entered a Show-Cause Order [17] when she failed to respond. On April 8, 2024, Shields filed a Response [18], then filed a second Response [19] on May 2, 2024. All four filings [1, 8, 18, 19] were considered by the Court. B. Facts Alleged Stated simply, Plaintiff takes issue with three Rule Violation Reports (RVR) and their consequences. Compl. [1] at 5; Resp. [18] at 1–2. The first RVR (issued on March 16, 2022) and the second RVR (issued on April 26,

2022) were for the same incident. Resp. [18] at 1. Plaintiff says that she “was removed from [her] job” and taken to the maximum-security unit at Central Mississippi Correctional Facility (CMCF). Id. She also complains that she lost the privilege of wearing “green/white pants.” Id. MDOC ultimately found Plaintiff not guilty and removed these RVRs from her file. Id. Plaintiff believes that her constitutional rights were violated because Defendants Cain, McDonald, and Mallett failed to follow MDOC Standard Operating Policy (SOP) #18-0101 or #19-01-01. Id.; Am. Compl. [8] at 1. Then on April 10, 2023, Plaintiff received a third RVR written by Defendant Matthews- Ellis while housed at DCF. Resp. [18] at 1. MDOC initially transferred Plaintiff to DCF restricted housing and then moved her to Walnut Grove Correctional Facility (WGCF). Id. at 2

(stating she was at WGCF from April to August). WGCF is an all-male maximum security prison, id., and Shields explains that she was “placed in . . . [the] Security Threat Group program.” Compl. [1] at 5. MDOC later transferred her to a maximum-security unit at CMCF. Resp. [18] at 2. That RVR was dismissed on June 5, 2023. Id. According to Shields, “All of the defendant violated the Plaintiff’s constitutional rights by placing her life in danger at an all male maximum security prison. And by disgracing her character!” Id. (unaltered). As relief, Plaintiff wants to be housed in general population, Compl. [1] at 5; reimbursed for court costs, id.; granted an injunction against Defendant Ellis “so she can’t do it again,” id.; reclassified to A-custody, id.; “upgrade[d] to green/white [pants],” Resp. [18] at 2; and “allowed to work at any job she . . . qua[l]ifies for,” id. II. Standard The Prison Litigation Reform Act (PLRA) applies to prisoners proceeding IFP and

provides that “the court shall dismiss the case at any time if the court determines that . . . (B) the action or appeal – (i) is frivolous or malicious; (ii) fails to state a claim on which relief may be granted; or (iii) seeks monetary relief against a defendant who is immune from such relief.” 28 U.S.C. § 1915(e)(2). Because Plaintiff proceeds IFP, her Complaint is subject to the case- screening procedures set out in the PLRA. III. Analysis Plaintiff sued Defendants under 42 U.S.C. § 1983. To state a claim under that statute, she “must allege facts showing that a person, acting under color of state law, deprived the plaintiff of a right, privilege or immunity secured by the United States Constitution or the laws of the United States.” Bryant v. Mil. Dep’t of Miss., 597 F.3d 678, 686 (5th Cir. 2010).

A. Due-Process Claims Shields says Defendants violated her constitutional rights, presumably by denying due process relating to her RVRs. To invoke the Due Process Clause, Plaintiff must have a protected liberty interest at stake. And, in the prison context, a constitutionally protected liberty interest is “generally limited to freedom from restraint which . . . imposes atypical and significant hardships on the inmate in relation to the ordinary incidents of prison life.” Sandin v. Conner, 515 U.S. 472, 484 (1995). Clothes and classifications. Shields claims an interest in the privileges of wearing green/white pants, being assigned a particular job, and receiving a certain custody classification. But “[p]risoners have no recognizable due process liberty interest in their custodial classification or various inmate privileges.” Toson v. Taylor, No. 23-10793, 2023 WL 8271965, at *1 (5th Cir. Nov. 30, 2023) (citing Butts v. Martin, 877 F.3d 571, 580 (5th Cir. 2017)). Thus, “the loss of various inmate privileges and a negative adjustment in [the prisoner’s] custodial status” are not

“atypical and significant hardship[s]” that violate a prisoner’s due-process rights. Id. (quoting Sandin, 515 U.S. at 484); see also Watkins v. Lnu, 547 F. App’x 409, 410 (5th Cir. 2013) (holding loss of privileges for commissary, visitation, and telephone did not implicate inmate’s liberty interest); Taylor v. Stanciel, 202 F. App’x 662, 663 (5th Cir. 2006) (noting “loss of privileges for 30 days does not give rise to a protected liberty interest”). Placement. Next, Shields says that she was placed in restricted housing at DCF for one week. Resp. [18] at 2. Then she was allegedly housed from April to August 2023 at WGCF, an “all[-]male maximum security prison,” id., and “placed in . . . [the] Security Threat Group program,” Compl. [1] at 5. Finally, she claims she was moved to CMCF from August until December 2023. Resp. [18] at 2.

Restricted or segregated confinement violates due process when it “imposes atypical or significant hardship” as it relates to the “ordinary incidents of prison life.” LaVergne v. Stutes, 82 F.4th 433, 436 (5th Cir. 2023) (citing Sandin, 515 U.S. at 484). The “courts should apply a nuanced analysis looking at the length and conditions of confinement on a case-by-case basis to determine whether they give rise to a liberty interest.” Carmouche v. Hooper, 77 F.4th 362, 367 (5th Cir. 2023) (citing Sandin, 515 U.S. at 484–85; Wilkerson v. Goodwin, 774 F.3d 845, 855–56 (5th Cir. 2014)). Shields asserts no facts about restricted housing and maximum security in her pleadings that present a viable constitutional violation. She asserts that she was moved between various facilities over the course of eight months and, at times, placed in segregation.

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Shields v. Mississippi Department of Corrections, Counsel Stack Legal Research, https://law.counselstack.com/opinion/shields-v-mississippi-department-of-corrections-mssd-2025.