Teryaeva-Reed v. Peters

Background

Julia Teryaeva-Reed, a federal prisoner proceeding without a lawyer, filed a civil-rights case against officials of the Federal Bureau of Prisons. The court separately granted her permission to proceed without paying the filing fee. She alleged that officials transferred her from the Federal Correctional Institution in Dublin, California, to the Federal Correctional Institution in Miami without medical clearance and screening for community placement.

According to the complaint, the transfer caused the loss of her prison job and property, delays in pursuing a sentence reduction and a compassionate-release motion, disruption of her social ties, and harm to her application for halfway-house placement. She also alleged that the Miami facility was comparable to a maximum-security prison and lacked a library, recreation, religious services, jobs, and meaningful programming for women. She sought money damages, placement in a halfway house or home confinement, or transfer to the Federal Correctional Institution in Tallahassee.

Court’s analysis

Because Teryaeva-Reed was proceeding without paying the filing fee, the court screened the complaint under 28 U.S.C. § 1915(e)(2). That statute requires dismissal if the action is frivolous, fails to state a claim for relief, or seeks money from a defendant who is immune from such relief. The court also noted that complaints filed without a lawyer must be read liberally, but still must include enough factual allegations to make a requested legal remedy plausible.

The court considered whether Teryaeva-Reed could pursue damages under an implied constitutional remedy, commonly called a Bivens claim, against federal officials. It explained that the Supreme Court has approved such damages remedies in only three contexts: unreasonable searches and seizures, gender discrimination under the Due Process Clause, and inadequate medical treatment. The court stated that expanding this remedy is disfavored and found no authority extending it to prison-transfer claims.

The court also held that the alleged transfer did not violate Teryaeva-Reed’s constitutional rights. Under the authorities cited by the court, prisoners have no constitutional right to incarceration at a particular institution, and a transfer to another prison does not itself violate due process or equal-protection rights even if the new institution is considerably less favorable.

Teryaeva-Reed separately alleged that officials’ decision to close the Dublin facility and transfer its inmates violated her First Amendment rights to free speech and access to the courts. The court explained that a prison-retaliation claim requires protected conduct, adverse action because of that conduct, a chilling effect on the prisoner’s rights, and the absence of a legitimate correctional purpose. It found that she did not identify protected speech or other conduct that led to the facility’s closure, and did not allege that the closure responded to her speech or lawsuits rather than to rulings in those lawsuits. The court also found no authority allowing a constitutional damages remedy for this retaliation theory.

Disposition

The court concluded that Teryaeva-Reed had not alleged a legally recognizable claim based on her transfer or the alleged retaliation. It dismissed the claims without leave to amend, meaning the court did not permit another amended complaint in this case. The court denied the motion for appointment of counsel, directed the clerk to enter judgment, and closed the file.