Lyde v. Green Haven Prison

Background

Jonathan Henry Lyde brought this action under 42 U.S.C. § 1983 while incarcerated. He proceeded without a lawyer and filed the action under 28 U.S.C. § 1915(a)(1). He alleged that, after being transferred from Great Meadow Correctional Facility to Green Haven Prison, he was placed in keeplock without a disciplinary ticket or note. His original complaint described 19 days of confinement; his amended complaint stated that the confinement lasted 18 days, from September 30 through October 17, 2019. He sought monetary damages.

In an order dated February 5, 2021, the court dismissed the claims against Green Haven because the facility is operated by the New York State Department of Corrections and Community Supervision, which the court treated as an arm of New York State and therefore immune from suit under the Eleventh Amendment. The court also treated the keeplock allegation as a Fourteenth Amendment procedural-due-process claim. It gave Lyde leave to amend by alleging facts showing that the conditions during keeplock were an atypical and significant hardship compared with ordinary prison life, and by naming the individuals personally involved in the alleged violation.

Amended Complaint

Lyde’s amended complaint again named Green Haven Prison as the only defendant. He repeated that he was placed in keeplock without a disciplinary ticket and alleged that he was initially told he would be released the next morning but remained confined for 18 days. He also alleged that, when he complained, “everyone laugh[ed] and made joke[s].” The amended complaint did not identify individual prison officials or describe conditions that were more severe or onerous than conditions in general population or in disciplinary or administrative segregation.

Court’s Analysis

The court held that the amended complaint did not correct the defects identified in the earlier order. Green Haven remained an improper defendant because of the immunity ruling under the Eleventh Amendment.

The court further held that Lyde failed to state a procedural-due-process claim. Under the rule applied by the court, a convicted prisoner does not have a protected liberty interest in a disciplinary hearing unless the punishment imposes an atypical and significant hardship compared with ordinary prison life. The court cited authority stating that restrictive confinement lasting less than 101 days generally does not create such an interest without facts showing unusually harsh conditions. Because Lyde alleged no such conditions during his 18 days in keeplock, the court dismissed the due-process claims for failure to state a claim on which relief could be granted under 28 U.S.C. § 1915(e)(2)(B)(ii).

Disposition

Judge Louis L. Stanton dismissed Lyde’s action under 28 U.S.C. § 1915(e)(2)(B)(i) and (ii), as reflected in the order’s conclusion, and directed the clerk to terminate the other pending matters. The order did not specify whether the dismissal was with or without prejudice. This was a screening and pleading ruling; the court did not reach a merits determination that the alleged keeplock placement was lawful or unlawful.