Washington v. Timekeeper NDOC

CourtDistrict Court, D. Nevada
DecidedDecember 31, 2024
Docket2:24-cv-01000
StatusUnknown

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

Bluebook
Washington v. Timekeeper NDOC, (D. Nev. 2024).

Opinion

1 UNITED STATES DISTRICT COURT

2 DISTRICT OF NEVADA

3 JOSEPH WASHINGTON, Case No. 2:24-cv-01000-GMN-DJA

4 Plaintiff, SCREENING ORDER v. 5 TIMEKEEPER NDOC, et al., 6 Defendants. 7 8 9 Plaintiff, who is incarcerated in the custody of the Nevada Department of 10 Corrections (“NDOC”), has submitted a civil rights complaint pursuant to 42 U.S.C. § 11 1983, and he has filed an application to proceed in forma pauperis. (ECF Nos. 1-1, 1.) A 12 decision on the application to proceed in forma pauperis is temporarily deferred. The 13 Court will now screen Plaintiff’s civil rights complaint under 28 U.S.C. § 1915A. 14 I. SCREENING STANDARD 15 Federal courts must conduct a preliminary screening in any case in which a 16 prisoner seeks redress from a governmental entity or officer or employee of a 17 governmental entity. See 28 U.S.C. § 1915A(a). In its review, the court must identify any 18 cognizable claims and dismiss any claims that are frivolous, malicious, fail to state a claim 19 upon which relief may be granted or seek monetary relief from a defendant who is immune 20 from such relief. See 28 U.S.C. § 1915A(b)(1),(2). Pro se pleadings, however, must be 21 liberally construed. Balistreri v. Pacifica Police Dep’t, 901 F.2d 696, 699 (9th Cir. 1990). 22 To state a claim under 42 U.S.C. § 1983, a plaintiff must allege two essential elements: 23 (1) the violation of a right secured by the Constitution or laws of the United States, and 24 (2) that the alleged violation was committed by a person acting under color of state law. 25 See West v. Atkins, 487 U.S. 42, 48 (1988). 26 In addition to the screening requirements under § 1915A, pursuant to the Prison 27 Litigation Reform Act (PLRA), a federal court must dismiss a prisoner’s claim, if “the allegation of poverty is untrue,” or if the action “is frivolous or malicious, fails to state a 1 claim on which relief may be granted, or seeks monetary relief against a defendant who 2 is immune from such relief.” 28 U.S.C. § 1915(e)(2). Dismissal of a complaint for failure 3 to state a claim upon which relief can be granted is provided for in Federal Rule of Civil 4 Procedure 12(b)(6), and the court applies the same standard under § 1915 when 5 reviewing the adequacy of a complaint or an amended complaint. When a court 6 dismisses a complaint under § 1915(e), the plaintiff should be given leave to amend the 7 complaint with directions as to curing its deficiencies, unless it is clear from the face of 8 the complaint that the deficiencies could not be cured by amendment. See Cato v. United 9 States, 70 F.3d 1103, 1106 (9th Cir. 1995). 10 Review under Rule 12(b)(6) is essentially a ruling on a question of law. See 11 Chappel v. Lab. Corp. of America, 232 F.3d 719, 723 (9th Cir. 2000). Dismissal for failure 12 to state a claim is proper only if it is clear that the plaintiff cannot prove any set of facts in 13 support of the claim that would entitle him or her to relief. See Morley v. Walker, 175 F.3d 14 756, 759 (9th Cir. 1999). In making this determination, the court takes as true all 15 allegations of material fact stated in the complaint, and the court construes them in the 16 light most favorable to the plaintiff. See Warshaw v. Xoma Corp., 74 F.3d 955, 957 (9th 17 Cir. 1996). Allegations of a pro se complainant are held to less stringent standards than 18 formal pleadings drafted by lawyers. See Hughes v. Rowe, 449 U.S. 5, 9 (1980). While 19 the standard under Rule 12(b)(6) does not require detailed factual allegations, a plaintiff 20 must provide more than mere labels and conclusions. Bell Atlantic Corp. v. Twombly, 550 21 U.S. 544, 555 (2007). A formulaic recitation of the elements of a cause of action is 22 insufficient. Id. 23 Additionally, a reviewing court should “begin by identifying pleadings [allegations] 24 that, because they are no more than mere conclusions, are not entitled to the assumption 25 of truth.” Ashcroft v. Iqbal, 556 U.S. 662, 679 (2009). “While legal conclusions can provide 26 the framework of a complaint, they must be supported with factual allegations.” Id. “When 27 there are well-pleaded factual allegations, a court should assume their veracity and then 1 whether a complaint states a plausible claim for relief . . . [is] a context-specific task that 2 requires the reviewing court to draw on its judicial experience and common sense.” Id. 3 Finally, all or part of a complaint filed by a prisoner may therefore be dismissed 4 sua sponte if the prisoner’s claims lack an arguable basis either in law or in fact. This 5 includes claims based on legal conclusions that are untenable (e.g., claims against 6 defendants who are immune from suit or claims of infringement of a legal interest which 7 clearly does not exist), as well as claims based on fanciful factual allegations (e.g., 8 fantastic or delusional scenarios). See Neitzke v. Williams, 490 U.S. 319, 327-28 (1989); 9 see also McKeever v. Block, 932 F.2d 795, 798 (9th Cir. 1991). 10 II. SCREENING OF COMPLAINT 11 In the complaint, Plaintiff sues multiple Defendants for events that took place while 12 he was incarcerated at High Desert State Prison (“HDSP”). (ECF No. 1-1 at 1.) Plaintiff 13 sues Defendants Timekeeper NDOC and Warden Bean. (Id. at 1-6.) Plaintiff brings one 14 count and seeks monetary relief. (Id. at 2-16.) 15 In the complaint, Plaintiff alleges that the Defendants conspired to deprive him of 16 credits toward his minimum sentence.1 (Id. at 2.) Under NRS 209.4465, the Defendants 17 were required to apply credits to Plaintiff’s minimum sentence, but they failed to do so. 18 (Id. at 3.) This extended the time until Plaintiff was eligible for parole. (Id.) Based on 19 these allegations, Plaintiff states that the Defendants violated his right to due process. 20 (Id.) 21 In order to state a Fourteenth Amendment due process claim, a plaintiff must 22 adequately allege that he was denied a specified liberty interest and that he was deprived 23 of that liberty interest without the constitutionally required procedures. Swarthout v. 24 Cooke, 562 U.S. 216, 219 (2011). In Nevada, state prisoners do not have a liberty interest 25 in parole or parole eligibility. See Moor v. Palmer, 603 F.3d 658, 661-62 (9th Cir. 2010); 26 Fernandez v. Nevada, No.

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Related

Hughes v. Rowe
449 U.S. 5 (Supreme Court, 1980)
West v. Atkins
487 U.S. 42 (Supreme Court, 1988)
Neitzke v. Williams
490 U.S. 319 (Supreme Court, 1989)
Moor v. Palmer
603 F.3d 658 (Ninth Circuit, 2010)
Ashcroft v. Iqbal
556 U.S. 662 (Supreme Court, 2009)
Edward McKeever Jr. v. Sherman Block
932 F.2d 795 (Ninth Circuit, 1991)
Michael Lacey v. Joseph Arpaio
693 F.3d 896 (Ninth Circuit, 2012)
Cato v. United States
70 F.3d 1103 (Ninth Circuit, 1995)
Keith v. Humphries
8 Ky. 13 (Court of Appeals of Kentucky, 1817)

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Washington v. Timekeeper NDOC, Counsel Stack Legal Research, https://law.counselstack.com/opinion/washington-v-timekeeper-ndoc-nvd-2024.