Simmons v. Ohio Adult Parole Authority

CourtDistrict Court, S.D. Ohio
DecidedMay 17, 2023
Docket2:23-cv-01566
StatusUnknown

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

Bluebook
Simmons v. Ohio Adult Parole Authority, (S.D. Ohio 2023).

Opinion

UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF OHIO EASTERN DIVISION

GRADY S. SIMMONS,

Plaintiff,

v. Civil Action 2:23-cv-1566 Judge Sarah D. Morrison Magistrate Judge Chelsey M. Vascura OHIO ADULT PAROLE AUTHORITY,

Defendant.

REPORT AND RECOMMENDATION Plaintiff, Grady S. Simmons, a state inmate who is proceeding without the assistance of counsel, brings this action against the Ohio Adult Parole Authority (“OAPA”) alleging that OAPA violated his procedural due process rights when denying Plaintiff’s application for parole. (Compl., ECF No. 1.) This matter is before the Court for the initial screen of Plaintiff’s Complaint under 28 U.S.C. § 1915A to identify cognizable claims and to recommend dismissal of Plaintiff’s Complaint, or any portion of it, which is frivolous, malicious, fails to state a claim upon which relief may be granted, or seeks monetary relief from a defendant who is immune from such relief. 28 U.S.C. § 1915A(b); see also McGore v. Wrigglesworth, 114 F.3d 601, 608 (6th Cir. 1997). Having performed the initial screen, for the reasons that follow, the undersigned RECOMMENDS that the Court DISMISS this action pursuant to § 1915A for failure to state a claim on which relief may be granted. I. STANDARD OF REVIEW To properly state a claim upon which relief may be granted, a plaintiff must satisfy the basic federal pleading requirements set forth in Federal Rule of Civil Procedure 8(a). See also Hill v. Lappin, 630 F.3d 468, 470–71 (6th Cir. 2010) (applying Federal Rule of Civil Procedure 12(b)(6) standards to review under 28 U.S.C. §§ 1915A and 1915(e)(2)(B)(ii)). Under Rule 8(a)(2), a complaint must contain a “short and plain statement of the claim showing that the pleader is entitled to relief.” Fed. R. Civ. P. 8(a)(2). Thus, Rule 8(a) “imposes legal and factual demands on the authors of complaints.” 16630 Southfield Ltd., P’Ship v. Flagstar Bank, F.S.B.,

727 F.3d 502, 503 (6th Cir. 2013). Although this pleading standard does not require “‘detailed factual allegations,’ . . . [a] pleading that offers ‘labels and conclusions’ or ‘a formulaic recitation of the elements of a cause of action’” is insufficient. Ashcroft v. Iqbal, 556 U.S. 662, 678 (2009) (quoting Bell Atlantic Corp. v. Twombly, 550 U.S. 544, 555 (2007)). A complaint will not “suffice if it tenders ‘naked assertion[s]’ devoid of ‘further factual enhancement.’” Id. (quoting Twombly, 550 U.S. at 557). Instead, to survive a motion to dismiss for failure to state a claim under Rule 12(b)(6), “a complaint must contain sufficient factual matter . . . to ‘state a claim to relief that is plausible on its face.’” Id. (quoting Twombly, 550 U.S. at 570). Facial plausibility is established “when the

plaintiff pleads factual content that allows the court to draw the reasonable inference that the defendant is liable for the misconduct alleged.” Id. “The plausibility of an inference depends on a host of considerations, including common sense and the strength of competing explanations for the defendant’s conduct.” Flagstar Bank, 727 F.3d at 504 (citations omitted). Further, the Court holds pro se complaints “to less stringent standards than formal pleadings drafted by lawyers.” Garrett v. Belmont Cty. Sheriff’s Dep’t, 374 F. App’x 612, 614 (6th Cir. 2010) (quoting Haines v. Kerner, 404 U.S. 519, 520 (1972)). This lenient treatment, however, has limits; “courts should not have to guess at the nature of the claim asserted.” Frengler v. Gen. Motors, 482 F. App’x 975, 976–77 (6th Cir. 2012) (quoting Wells v. Brown, 891 F.2d 591, 594 (6th Cir. 1989)). II. ANALYSIS Plaintiff alleges that he was denied due process at his parole hearing because the OAPA had pre-determined that it would deny Plaintiff’s request for parole, based on a “49-rule- combination,” before Plaintiff’s parole hearing took place. (Compl., ECF No. 1.) Plaintiff seeks immediate release from custody and $4.85 million in damages. (Id.)

Plaintiff has failed to allege a colorable due process claim. “A plaintiff bringing a § 1983 action for procedural due process must show that the state deprived him or her of a constitutionally protected interest in ‘life, liberty, or property’ without due process of law.” Swihart v. Wilkinson, 209 F. App’x 456, 458 (6th Cir. 2006) (citing Zinermon v. Burch, 494 U.S. 113, 125 (1990)). Thus, because Plaintiff seeks to establish a due process violation relating to the OAPA’s consideration of his parole eligibility, he “must first show that he . . . has a protected property or liberty interest in parole.” Settle v. Tenn. Dep’t of Corrs., 487 F. App’x 290, 290–91 (6th Cir. 2012) (citations omitted). “A liberty interest in parole eligibility derives only from state law.” Id. at 291 (citations omitted); see also Jackson v. Jamrog, 411 F.3d 615, 619 (6th Cir. 2005) (“[T]here is no fundamental right to parole under the federal constitution.”). If a state’s

statutes vest complete discretion in the parole board to determine eligibility for parole, no liberty interest exists. See Ky. Dep’t of Corr. v. Thompson, 490 U.S. 454, 464–65 (1989) (discretionary prison policies do not create liberty interests implicating the Fourteenth Amendment). Here, “Ohio does not give inmates a right to parole; the Board has authority to grant or deny a candidate’s application at its discretion.” Bailey v. Wainwright, 951 F.3d 343, 346 (6th Cir. 2020) (citing State ex rel. Keith v. Ohio Adult Parole Auth., 24 N.E.3d 1132, 1135–36 (2014)). Because Ohio has a completely discretionary parole system, “Ohio law does not create a protected liberty interest in release from parole.” Jergens v. State of Ohio Dep’t of Rehab. & Corrs. Adult Parole Auth., 492 F. App’x 567, 570 (6th Cir. 2012). As a result, Plaintiff is unable to state a viable § 1983 due process claim challenging the OAPA Board’s eligibility determination. Accordingly, it is RECOMMENDED that the Court DISMISS Plaintiff’s due process claim pursuant to § 1915A(b)(1). III. DISPOSITION For the reasons set forth above, it is RECOMMENDED that the Court DISMISS

Plaintiff’s Complaint in its entirety pursuant to 28 U.S.C. § 1915A.

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Related

Jeremy Garrett v. Belmont County Sheriff's Dep't
374 F. App'x 612 (Sixth Circuit, 2010)
Haines v. Kerner
404 U.S. 519 (Supreme Court, 1972)
Thomas v. Arn
474 U.S. 140 (Supreme Court, 1986)
Kentucky Department of Corrections v. Thompson
490 U.S. 454 (Supreme Court, 1989)
Bell Atlantic Corp. v. Twombly
550 U.S. 544 (Supreme Court, 2007)
Ashcroft v. Iqbal
556 U.S. 662 (Supreme Court, 2009)
Hill v. Lappin
630 F.3d 468 (Sixth Circuit, 2010)
Paul Jackson v. David Jamrog, Warden
411 F.3d 615 (Sixth Circuit, 2005)
Neil Frengler v. General Motors
482 F. App'x 975 (Sixth Circuit, 2012)
Zinermon v. Burch
494 U.S. 113 (Supreme Court, 1990)
State ex rel. Keith v. Ohio Adult Parole Auth. (Slip Opinion)
2014 Ohio 4270 (Ohio Supreme Court, 2014)
Swihart v. Wilkinson
209 F. App'x 456 (Sixth Circuit, 2006)
Mike Settle v. Tennessee Dep't of Corrections
487 F. App'x 290 (Sixth Circuit, 2012)
Michael Bailey v. Lyneal Wainwright
951 F.3d 343 (Sixth Circuit, 2020)
Wells v. Brown
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Simmons v. Ohio Adult Parole Authority, Counsel Stack Legal Research, https://law.counselstack.com/opinion/simmons-v-ohio-adult-parole-authority-ohsd-2023.