Shatswell v. Taylor
- Edward Chen
- 3:19-cv-06883
- U.S. District Court · Northern District of California
- 5
In Shatswell v. Taylor, Judge Chen dismissed the prison-education civil-rights action for failure to state a claim and denied a requested stay.
Danny Michael Shatswell’s federal civil-rights action was dismissed, and his request to pause the case was denied; the order resolved the claims against J. Taylor and the other defendants named in the complaint.
What happened
In Shatswell v. Taylor, Danny Michael Shatswell alleged that prison officials improperly removed him from college and denied him the opportunity to earn a General Educational Development certificate, affecting possible release credits. He sought damages under a federal civil-rights law.
The court ruled that prisoners have no constitutional right to prison education. It also found that Shatswell could not plausibly show that officials deprived him of educational credits: he already had earned his certificate before his current incarceration and had not shown he could have completed a college degree before his prison term ended.
Judge Edward Chen dismissed the action for failure to state a claim and did not allow an amended complaint because amendment would be futile. The court also denied Shatswell’s motion to seal, treating it as a request to pause the case.
The detailed version
- Shatswell v. Taylor · No. 3:19-cv-06883
- Edward Chen
- Jan. 14, 2020
Background
Danny Michael Shatswell, who was formerly incarcerated at the Correctional Training Facility in Soledad and was then incarcerated at Santa Rita Jail, filed the action without a lawyer under 42 U.S.C. § 1983. That statute allows a person to seek relief for a violation of federal rights by someone acting under state law. The court reviewed the complaint under the prisoner-screening statute, 28 U.S.C. § 1915A. Shatswell also filed a motion to seal the action.
Shatswell alleged that prison officials improperly removed him from a college program that could have helped him earn an earlier release. He also alleged that officials denied him the opportunity to earn a General Educational Development certificate and refused to recognize a copy of his existing certificate because it was not a sealed original. He sought damages.
Court’s reasoning
The court explained that prisoners do not have a constitutional right to educational opportunities in prison. Because Shatswell’s allegations concerned his inability to enroll in General Educational Development or college courses, the court concluded that the alleged actions did not violate the Constitution.
The court separately considered Shatswell’s apparent concern about educational merit credits under California regulations. The regulation allowed certain credits for educational achievements but limited credits for a high school diploma or equivalent when the prisoner already possessed one before the current incarceration. Shatswell’s complaint stated that he obtained his General Educational Development certificate in 1988, before his current term, so he could not obtain that credit under the regulation.
The court also found that Shatswell had not plausibly alleged that he would have earned a college degree in time to receive the available credit. He had started one three-unit course in fall 2018, did not enroll in or complete other courses according to his transcript, and was released from state custody by November 17, 2019. The court found it implausible that he could have completed enough coursework for an associate’s or bachelor’s degree before the end of his prison term, even without the defendants’ alleged actions.
Disposition
The court dismissed the action for failure to state a claim. It did not grant leave to amend because amendment would be futile: the Constitution does not guarantee a right to education in prison.
The court construed Shatswell’s motion to seal as a motion to stay, meaning a request to pause the case, and denied that motion. The court stated that no further action was required from Shatswell because the case was being dismissed. Judge Edward Chen signed the order on January 14, 2020.
Read the full 5-page opinion on CourtListener, the free public archive maintained by the Free Law Project.