Castillo v. Snedeker

Background

Pedro Castillo, who was incarcerated at Sing Sing Correctional Facility, filed this case without a lawyer and without paying the filing fee under 42 U.S.C. § 1983. He alleged that C.O. Robert C. Snedeker, First Deputy Superintendent Donald Venettozzi, and C.H.O. Katherine Henley violated his rights under the Eighth and Fourteenth Amendments during his confinement at Green Haven Correctional Facility from December 2015 through April 2016.

In a prior order, the court dismissed Castillo’s claim against Snedeker based on an allegedly false misbehavior report without prejudice, meaning Castillo could try to replead it. The court dismissed with prejudice, meaning the claims could not be refiled, Castillo’s Fourteenth Amendment due-process claims against Henley and Venettozzi and his Eighth Amendment conditions-of-confinement claim. The court allowed Castillo to amend only the false-misbehavior-report claim against Snedeker.

Motion and analysis

Snedeker moved to dismiss the amended complaint under Federal Rule of Civil Procedure 12(b)(6), which permits dismissal when a complaint does not state a legally recognized claim. The court explained that an incarcerated person generally has no standalone constitutional right to be free from a false disciplinary report. Such a claim may proceed if the report led to discipline without adequate procedures or if it was issued in retaliation for exercising a constitutional right.

The court had previously found that Castillo was not denied due process because of the report and had not alleged that Snedeker issued it in retaliation for protected conduct. The amended complaint did not add allegations that Castillo had engaged in protected conduct. Castillo also stated in his unauthorized sur-reply that retaliation was not his claim. The court therefore concluded that the amended complaint did not state a legally cognizable claim based on Snedeker’s allegedly false report.

Disposition

The court granted Snedeker’s motion to dismiss Castillo’s false-misbehavior-report claim with prejudice. The court also dismissed with prejudice Castillo’s Fourteenth Amendment due-process claim against Snedeker, reasoning that Castillo had already been given an opportunity to correct the identified defects and that another amendment would be futile.

The court did not reach Snedeker’s qualified-immunity argument. It certified that an appeal would not be taken in good faith and denied Castillo permission to appeal without paying the filing fee. The Clerk was directed to terminate the motion, mail the opinion to Castillo, and close the case.