Valanju v. Federal Bureau of Prisons

CourtDistrict Court, D. South Carolina
DecidedAugust 6, 2025
Docket4:25-cv-05330
StatusUnknown

This text of Valanju v. Federal Bureau of Prisons (Valanju v. Federal Bureau of Prisons) 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
Valanju v. Federal Bureau of Prisons, (D.S.C. 2025).

Opinion

UNITED STATES DISTRICT COURT DISTRICT OF SOUTH CAROLINA Divesh Valanju, #70619-018, ) C/A No. 4:25-5330-RMG-TER Plaintiff, ) ) vs. ) Report and Recommendation ) Federal Bureau of Prisons, ) F.C.I. Williamsburg, ) Defendants. ) ___________________________________________) This is a civil action filed by a federal prisoner, proceeding pro se. Pursuant to 28 U.S.C. § 636(b)(1) and District of South Carolina Local Civil Rule 73.02(B)(2)(e), the undersigned is authorized to review all pretrial matters in such pro se cases and to submit findings and recommendations to the district court. Plaintiff paid the filing fee. STANDARD OF REVIEW Under established local procedure in this judicial district, a careful review has been made of the pro se complaint filed in this case. This review has been conducted pursuant to the procedural provisions of 28 U.S.C. § 1915A, and the Prison Litigation Reform Act of 1996, and in light of the following precedents: Denton v. Hernandez, 504 U.S. 25 (1992); Neitzke v. Williams, 490 U.S. 319, 324-25 (1989); Haines v. Kerner, 404 U.S. 519 (1972); Nasim v. Warden, Md. House of Corr., 64 F.3d 951 (4th Cir.1995) (en banc); Todd v. Baskerville, 712 F.2d 70 (4th Cir.1983). This court is required to liberally construe pro se complaints. Erickson v. Pardus, 551 U.S. 89, 94 (2007). Such pro se complaints are held to a less stringent standard than those drafted by attorneys. Id. ; Gordon v. Leeke, 574 F.2d 1147, 1151 (4th Cir. 1978). Even under this less stringent standard, however, the pro se complaint is subject to summary dismissal. The mandated liberal construction afforded to pro se pleadings means that if the court can reasonably read the pleadings to state a valid claim on which plaintiff could prevail, it should do so, but a district court may not rewrite a complaint to include claims that were never presented, construct the plaintiff’s legal arguments for him, or conjure up questions never squarely presented to the court. Beaudett v. City of Hampton, 775 F.2d 1274, 1278 (4th Cir. 1985); Small v. Endicott, 998 F.2d 411 (7th Cir. 1993);

Barnett v. Hargett, 174 F.3d 1128 (10th Cir. 1999). The requirement of liberal construction does not mean that the Court can ignore a clear failure in the pleading to allege facts which set forth a claim currently cognizable in a federal district court. Weller v. Dep’t of Soc. Servs., 901 F.2d 387, 390-91 (4th Cir. 1990) (The “special judicial solicitude” with which a [court] should view such pro se complaints does not transform the court into an advocate.). DISCUSSION The crux of Plaintiff’s Complaint is that he has not been allowed to use Trulincs, the service

the BOP uses for prisoners to send electronic messages. (ECF No. 1). Plaintiff attempts to couch this as a claim under the Administrative Procedures Act (APA). (ECF No. 1). Plaintiff alleges his mail never reaches its destinations in India. (ECF No. 1 at 2). Plaintiff himself notes “the warden has discretion to make that determination to deny Plaintiff the privilege of emails access.” (ECF No. 1 at 3). First, Defendant F.C.I. Williamsburg is not a proper party and is subject to summary dismissal, as it is a building and not an agency. The analysis proceeds as to the federal agency Defendant FBOP.

APA “Section 3625 of Title 18 of the United States Code clearly states that the APA does not apply to prisoners.” Searcy v. Fed. Bureau of Prisons, No. 6:07-CV-3146GRA, 2007 WL 4322152, 2 at *3 (D.S.C. Dec. 6, 2007). Courts may review BOP action or policy that violates the Constitution. See Myers v. Williams, 2015 WL 13735447, at *5 (N.D.W. Va. Oct. 19, 2015) (citing Webster v. Doe, 486 U.S. 592 (1988); Turner v. Safley, 482 U.S. 78, 84 (1987); Procunier v. Martinez, 416 U.S. 396, 405 (1974)). However, prisoners have no First Amendment constitutional right to access email.

Grayson v. Fed. Bureau of Prisons, 2012 WL 380426, at *3 (N.D.W. Va. Feb. 6, 2012); Hower v. Stewart, 2018 WL 4384150, at *8 (D. Md. Sept. 14, 2018)(collecting cases). The BOP’s guidelines are “internal agency guidelines, which are not subject to the rigors of APA.” Rice v. Hogsten, 2014 WL 4656119, at *5 (S.D.W. Va. Sept. 16, 2014). Plaintiff has failed to state a claim upon which relief could be granted under the APA. FTCA As a matter of liberal construction and because the Defendant named is an agency, the court

considers whether Plaintiff’s allegations state a claim under the FTCA. A claim against an agency like FBOP would be under the FTCA and requires exhaustion under Standard Form 95. Plaintiff has not alleged that he has exhausted any liberally construed FTCA claim. Further, even if Plaintiff exhausted under the FTCA, the discretionary function exception here would bar Plaintiff’s claims. The discretionary function exception is intended “to prevent judicial ‘second-guessing’ of legislative and administrative decisions grounded in social, economic, and political policy through the medium of an action in tort.” United States v. Varig Airlines, 467 U.S. 797, 814 (1984). The Fourth Circuit has found that this discretionary function exception applies (1) when the act or omission “involves

an element of judgment or choice” and (2) when this “judgment was one that the exception was designed to protect, namely, a judgment based on considerations of public policy.” Rich v. United States, 811 F.3d 140, 144 (4th Cir. 2015). The FBOP’s response to Plaintiff’s grievances and the 3 program statement 4500.12 show that Trulincs participation decisions are based on individual history of behavior, no inmate is entitled to access, and each request is considered on a case-by-case basis. Plaintiff has failed to state a claim under the FTCA. Bivens

As a matter of liberal construction, the court considers whether Plaintiff states a Bivens claim. No individual defendant has been sued here and no Bivens claim has been recognized for the First Amendment.1 “The Supreme Court has never recognized a First Amendment based Bivens remedy in any context.” Earle v. Shreves, 990 F. 3d 774, 779 (4th Cir. 2021) (citing Reichle v. Howards, 566 U.S. 658, 663 n.4 (2012) (“We have never held that Bivens extends to First Amendment claims”)); Egbert v. Boule, 596 U.S. 482, 498–99 (2022). Liberally construed, Plaintiff has failed to state a Bivens claim.

In Plaintiff’s attachments, Plaintiff stated “as per my conviction, there is no use of email system in my case.” (ECF No. 1 at 18).

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Related

Haines v. Kerner
404 U.S. 519 (Supreme Court, 1972)
Procunier v. Martinez
416 U.S. 396 (Supreme Court, 1974)
Harlow v. Fitzgerald
457 U.S. 800 (Supreme Court, 1982)
Thomas v. Arn
474 U.S. 140 (Supreme Court, 1986)
Turner v. Safley
482 U.S. 78 (Supreme Court, 1987)
Webster v. Doe
486 U.S. 592 (Supreme Court, 1988)
Neitzke v. Williams
490 U.S. 319 (Supreme Court, 1989)
Denton v. Hernandez
504 U.S. 25 (Supreme Court, 1992)
Erickson v. Pardus
551 U.S. 89 (Supreme Court, 2007)
United States v. Edward Lester Schronce, Jr.
727 F.2d 91 (Fourth Circuit, 1984)
Luther K. Barnett, Jr. v. Steve Hargett
174 F.3d 1128 (Tenth Circuit, 1999)
Reichle v. Howards
132 S. Ct. 2088 (Supreme Court, 2012)
Joshua Rich v. United States
811 F.3d 140 (Fourth Circuit, 2015)
Vernon Earle v. Shreves
990 F.3d 774 (Fourth Circuit, 2021)

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Bluebook (online)
Valanju v. Federal Bureau of Prisons, Counsel Stack Legal Research, https://law.counselstack.com/opinion/valanju-v-federal-bureau-of-prisons-scd-2025.