Jackson v. Mike-Lopez

Background

Ronnie Jackson, Joshua Jones, Shane Kringen, Marvin Franco-Morales, Mitchell Osterloh, and Jesse Plentyhorse, all proceeding without lawyers, sued Sharlene Mike-Lopez, Diane Medchill, Kathy Reid, Bruce Reiser, David Reishus, Michelle Smith, and Tom Roy in their individual capacities under 42 U.S.C. § 1983. The plaintiffs alleged violations of the Eighth Amendment, Fourteenth Amendment, and First Amendment based on their confinement in the Administrative Control Unit at MCF-Oak Park Heights between May 1 and July 31, 2017, and their later placement on Administrative Control Status.

The plaintiffs alleged that they spent at least 80 days in segregation, often 23 hours per day in small cells. They described unclean cells and laundry, feces and other bodily fluids on walls and ceilings, stained mattresses, limited visitation, inadequate privacy, artificial lighting, loud neighboring prisoners, limited exercise, and restrictions on preferred religious services. They also alleged that their mental-health symptoms worsened and that defendants placed them in Administrative Control Status and required participation in a mental-health treatment program without the procedures they believed were required.

Motion to Dismiss

The defendants moved to dismiss under Federal Rule of Civil Procedure 12(b)(6), which tests whether a complaint states a legally sufficient claim. Because the case was at the motion-to-dismiss stage, the court accepted the plaintiffs’ factual allegations as true for purposes of the motion.

Eighth Amendment conditions claim

The court concluded that the plaintiffs plausibly alleged an unconstitutional conditions-of-confinement claim against Mike-Lopez. The alleged combination of filthy conditions, human waste, stained mattresses, and confinement for almost three months, together with 23-hour-per-day cell confinement and limited opportunity for exercise, was sufficient at the pleading stage. The plaintiffs also alleged that Mike-Lopez knew about the conditions.

Eighth Amendment medical claim

The court concluded that the plaintiffs did not plausibly allege deliberate indifference to serious medical needs. They alleged that segregation worsened their mental-health symptoms, but they did not allege that any particular defendant knew about and deliberately disregarded a serious medical need. General allegations against the defendants as a group were insufficient.

Fourteenth Amendment due-process claim

The court concluded that the plaintiffs failed to state a due-process claim based on their placement in administrative segregation or the required treatment program. The opinion explained that the plaintiffs needed to allege an atypical and significant hardship compared with ordinary prison life, and found that the alleged three-month segregation period and treatment-program participation did not meet that standard.

Religious-exercise claims

The plaintiffs alleged that segregation prevented participation in religious practices, including Native American Sweat Lodge, Catholic services, Astru practices, and Muslim feasts. The court found that these allegations could plausibly describe a substantial burden on religious exercise. It nevertheless concluded that the plaintiffs did not plausibly allege that any defendant was personally involved in placing them in the segregation that caused the burden. The court therefore found that the plaintiffs failed to state claims under the First Amendment or the Religious Land Use and Institutionalized Persons Act.

Available relief

The court concluded that the plaintiffs could not obtain declaratory or injunctive relief concerning the Administrative Control Unit because they were no longer confined there, making those requests moot. It also concluded that the Prison Litigation Reform Act barred compensatory damages for mental or emotional injury because the plaintiffs had not alleged a separate physical injury. The court found that the plaintiffs had stated a claim for punitive damages related to the surviving conditions-of-confinement claim against Mike-Lopez.

Other motions and disposition

The court denied Jackson’s motion for spoliation, which alleged that defendants had destroyed evidence or legal documents. It also denied Jackson’s emergency motion for fines and sanctions, concluding that he had not complied with the required procedure for serving a sanctions motion and that the conduct described was not sanctionable.

The court ordered that both of Jackson’s motions be DENIED. It recommended that the defendants’ motion to dismiss be GRANTED IN PART and DENIED IN PART. The document identifies itself as a report and recommendation rather than a final order or judgment and states that objections could be filed within the specified period.