Shatswell v. Taylor
- Edward Chen
- 3:19-cv-06883
- U.S. District Court · Northern District of California
- 3
In Shatswell v. Taylor, Judge Chen denied reconsideration of dismissal over prison education and merit-credit claims.
Danny Michael Shatswell, whose motion for reconsideration was denied; the order also concerns defendants J. Taylor and the other named defendants.
What happened
In Shatswell v. Taylor, the court had dismissed Danny Michael Shatswell’s claims that he was improperly removed from a college program and denied a chance to earn a second G.E.D. The court previously ruled that he had not stated a claim under a federal civil-rights law because there is no federal constitutional right to education in prison and his allegations did not plausibly show he could earn Educational Merit Credits before his prison term ended.
Shatswell asked the court to reconsider, saying he had read case law supporting his position and had taken college courses earlier in life that might help him earn a second associate’s degree. The court found that he had not shown new evidence, a clear mistake, or a change in the law. It also noted that the applicable regulation required him to earn at least half of the units needed for a second associate’s degree during his current prison term, which he had not alleged.
Judge Edward Chen denied Shatswell’s motion for reconsideration. The court reaffirmed that Shatswell had not plausibly shown he could earn enough credits in the available time and that there is no federal constitutional right to education in prison.
The detailed version
- Shatswell v. Taylor · No. 3:19-cv-06883
- Edward Chen
- Feb. 10, 2020
Background
The court had previously dismissed Danny Michael Shatswell’s action because his complaint failed to state a claim for relief. He alleged that he was improperly removed from a college program and denied the opportunity to earn a second G.E.D. The earlier order concluded that he had not stated a claim under 42 U.S.C. § 1983, a federal civil-rights statute that allows claims for violations of constitutional rights by state actors.
The court explained that there is no federal constitutional right to an education in prison. It also found that Shatswell had not plausibly alleged that he was deprived of Educational Merit Credits. His transcript showed that he had started only one three-unit class in Fall 2018, while his prison term ended on November 17, 2019. The court concluded that it was not plausible that he could have taken enough courses in the remaining one or two terms to earn a college degree.
Motion for Reconsideration
Shatswell moved for reconsideration under Federal Rule of Civil Procedure 59(e). He argued that he had read case law stating that there was a right to education and that college courses he had taken earlier in life might help him earn a second Associate of Science degree.
A Rule 59(e) motion may be used to alter or amend a judgment, but reconsideration generally requires newly discovered evidence, clear error by the court, or an intervening change in controlling law. The court found that Shatswell had shown none of those circumstances.
The court also rejected his argument about a second associate’s degree. Even if the governing regulation allowed an inmate to earn Educational Merit Credits for obtaining a second associate’s degree, the regulation required the inmate to earn at least 50 percent of the units needed for that degree during the current prison term. Shatswell did not allege that he had already earned enough qualifying credits during that term to obtain the degree before his term ended.
Ruling
Judge Edward Chen denied Shatswell’s motion for reconsideration. The court held that he had not alleged facts plausibly showing that he could have earned enough credits in the short period available to receive Educational Merit Credits. The court also reiterated that there is no federal constitutional right to education in prison.
Read the full 3-page opinion on CourtListener, the free public archive maintained by the Free Law Project.