Anderson v. Rios

Background

Dexter Anderson, proceeding without a lawyer, was confined in the Special Housing Unit at the Federal Prison Camp in Duluth. He alleged that the Bureau of Prisons planned to transfer him to another facility. Anderson sought a temporary restraining order and preliminary injunction to prevent the transfer.

Anderson asserted two grounds for emergency relief. First, he said that two medical conditions required follow-up appointments and treatment that he might miss if transferred. Second, he alleged that prison officials disciplined him and planned to transfer him in retaliation for his exercise of First Amendment rights through filing grievances.

Magistrate Judge Katherine Menendez recommended denying the motion because Anderson had not satisfied the factors for emergency injunctive relief. Anderson objected to that recommendation.

Court’s analysis

The court reviewed the portions of the recommendation to which Anderson specifically objected. It considered four factors: the likelihood that Anderson would succeed on his claims, the threat of irreparable harm, the balance of harms to the parties, and the public interest.

As to Anderson’s claim that prison officials were deliberately indifferent to his medical needs, the court found that he had not provided evidence connecting the planned transfer to an actionable injury or otherwise established the elements of that claim. The court noted that the Federal Prison Camp in Duluth knew about Anderson’s medical issues and had coordinated follow-up appointments consistent with an oncologist’s recommendations. The facility also agreed not to transfer him before an ear, nose, and throat appointment, before medical staff received an orthopedist’s report, or if further treatment for his chronic arthritis made transfer inappropriate.

The court also rejected Anderson’s objection concerning irreparable harm. It stated that a person seeking a temporary restraining order or preliminary injunction must show irreparable harm and found that the facility’s precautions would prevent the transfer from delaying his medical care.

Regarding the alleged retaliatory transfer, the court explained that Anderson had to provide affirmative evidence that retaliation was the reason he would not otherwise have been disciplined or transferred. The court further stated that a retaliation claim fails when the challenged action resulted from an actual prison-rule violation, and that some evidence of a violation can defeat such a claim. The record showed that Anderson had been written up for at least five incidents of misbehavior between June and August 2018, and that the incidents were substantiated and resulted in sanctions. The court therefore agreed that Anderson was unlikely to succeed on the retaliation claim.

Finally, the court concluded that the public-interest and balance-of-harms factors weighed against emergency relief. It found that Anderson had not shown a threat of irreparable harm and that an injunction would interfere with prison administration.

Disposition

Judge Susan Richard Nelson overruled Anderson’s objections, adopted Magistrate Judge Menendez’s report and recommendation in its entirety, and denied Anderson’s motion for a temporary restraining order and preliminary injunction. The opinion did not enter a final ruling on the underlying medical-care or retaliation claims; it ruled on Anderson’s request for emergency injunctive relief.