ADAMS v. PENFOLD, 2:17-cv-00368

Plaintiff Benjamin Adams, an Indiana prisoner, challenged a December 2016 prison disciplinary conviction (IYC-16-11-0176) for trafficking in a synthetic drug and sought damages and injunctive relief under 42 U.S.C. § 1983.
Adams alleges due process violations at his December 29, 2016 disciplinary hearing: DHO J. Peltier refused to call requested witnesses, and administrative assistant C.A. Penfold failed to dismiss the charge despite a 21-day delay between investigation completion and the charge.
Adams claims Penfold applied inconsistent practice by not dismissing his case although she has dismissed other disciplinary actions not charged within seven days of investigation completion, raising an equal protection claim.
While Adams’ administrative appeals were pending and after he filed a habeas action challenging the conviction, prison officials vacated the conviction and sanctions and scheduled a rehearing.
The district court screened the pro se complaint under 28 U.S.C. § 1915A and found no viable § 1983 claims, dismissing the complaint but giving Adams an opportunity to show cause why the dismissal should not be entered.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Procedural due process at disciplinary hearing	Adams: Peltier refused to hear requested witnesses, denying due process	Defendants: Any procedural irregularity does not create a constitutional violation; remedies lie in habeas, not § 1983	Court: No due process claim; procedural errors or policy violations do not automatically state a § 1983 claim
Equal protection based on inconsistent application of dismissal policy	Adams: Penfold treated him differently by not dismissing despite delay, showing unequal treatment	Defendants: Adams does not allege membership in a protected class or intentional discrimination on that basis	Court: No equal protection claim; allegation of unfair treatment alone insufficient without class-based discrimination
Injunctive relief to expunge conviction (habeas-type relief)	Adams: Requests injunction to dismiss IYC-16-11-0176 and expunge trafficking conviction	Defendants: Relief sought is habeas in nature, not proper in a civil-rights action	Court: Requested relief is a habeas remedy; not available in § 1983 action, claim dismissed
Failure to follow prison policy / internal procedures	Adams: Violations of prison policy (e.g., timeliness) support his claims	Defendants: Violation of internal policy does not create federal constitutional rights	Court: Policy noncompliance does not amount to a constitutional violation under § 1983

Erickson v. Pardus, 551 U.S. 89 (clarifying pro se complaint standard under Rule 8)
Bell Atl. Corp. v. Twombly, 550 U.S. 544 (pleading must raise right to relief above speculative level)
Windy City Metal Fabricators & Supply, Inc. v. CIT Tech. Fin. Servs., 536 F.3d 663 (plausibility standard for pleadings)
Tamayo v. Blagojevich, 526 F.3d 1074 (pleading standards in Seventh Circuit)
Obriecht v. Raemisch, 517 F.3d 489 (liberal construction for pro se pleadings)
Estelle v. McGuire, 502 U.S. 62 (state-law violations do not support federal habeas relief)
Owens v. Hinsley, 635 F.3d 950 (prison official’s handling of grievances not basis for § 1983 absent participation in underlying conduct)
Herro v. City of Milwaukee, 44 F.3d 550 (equal protection requires class-based intentional discrimination)
Huebschen v. Dep’t of Health & Soc. Servs., 716 F.2d 1167 (different treatment alone insufficient for equal protection)
Gladney v. Pendleton Corr. Facility, 302 F.3d 773 (§ 1915A screening authority)
Luevano v. Wal-Mart Stores, Inc., 722 F.3d 1014 (requirement to give in forma pauperis plaintiffs opportunity to amend or show cause)