Oden v. Reed

Background

Terrell Oden, a state prisoner proceeding without a lawyer, filed a civil-rights lawsuit under 42 U.S.C. § 1983 against officers at the Correctional Training Facility. The court stated that it would address Oden’s request to proceed without paying the filing fee in a separate order.

Oden alleged that Lt. J. Reed retaliated against him after he filed a grievance against Officer Z. Brown. The grievance concerned a Rules Violation Report charging Oden and several other inmates with theft of state funds exceeding $400. Oden alleged that the other prisoners were cleared of the charges, while he appeared before Reed on March 15, 2022, and was found guilty of a lesser charge. He claimed that Reed’s action chilled his exercise of protected conduct and did not advance a legitimate prison-related goal.

Oden separately alleged that Sgt. J. Peffley, who was part of the Prison Investigative Services Unit, prepared an incident report that disclosed Oden’s personal identifying information to other inmates. Oden claimed that the disclosure violated state regulations and was negligent, deliberate, reckless, and unlawful.

Screening standard

Because Oden is a prisoner suing governmental officers, the court was required to conduct an initial screening under 28 U.S.C. § 1915A. The court had to dismiss claims that failed to state a claim for relief or sought money from an immune defendant. It also stated that pleadings filed without a lawyer must be read liberally.

To state a claim under § 1983, a plaintiff must allege both a violation of a right secured by the Constitution or federal law and conduct by a person acting under state law.

Court’s analysis and rulings

The court found that Oden stated a legally recognizable retaliation claim against Reed. The claim was based on the alleged adverse action—the guilty finding—after Oden engaged in protected conduct, together with his allegation that the action had a chilling effect and lacked a reasonable legitimate prison-related purpose.

The court dismissed Oden’s separate state-law privacy claim against Peffley for failure to state a claim for relief under § 1983. It also ruled that the state privacy claim was not sufficiently related to the federal retaliation claim to support supplemental jurisdiction, meaning the federal court would not hear the state-law claim as part of this case. The court directed Oden to pursue that claim in state court and directed the clerk to terminate Peffley from the action.

Next steps ordered

The court ordered that Reed be served at the Correctional Training Facility. It directed the defendants to file a summary-judgment motion concerning the claim found legally sufficient, or to notify the court if summary judgment was not appropriate, within 91 days after the order was filed. It set deadlines for Oden’s opposition and the defendants’ reply, allowed discovery under the Federal Rules of Civil Procedure, and stated that no hearing would be held unless the court later ordered one.