2:17-cv-11736
E.D. Mich.Aug 11, 2017Background
- Plaintiff Jonathan Barnett is an incarcerated Michigan prisoner; he married Teri Jackson, a probationer, in 2016.
- Jackson pled guilty to furnishing a cell phone to a prisoner and is prohibited by a probation condition from contacting anyone she knows to be a convicted felon.
- As a result of that probation condition and her probation officer’s decision, Jackson was removed from Barnett’s approved visitor list at Central Michigan Correctional Facility.
- Barnett sued Jackson’s probation officers (Cynthia Migan and Amanda Wagner) seeking a temporary restraining order and preliminary injunction to prohibit enforcement of the association ban.
- After Barnett filed suit, a supervisory official lifted the no-communication restriction between Jackson and Barnett, but visitation still required the facility warden’s approval under MDOC policy.
- The district court denied injunctive relief and dismissed the complaint without prejudice, holding Barnett lacks Article III standing to challenge his wife’s probation condition.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Standing to challenge third party’s probation condition | Barnett argues he is injured by Jackson’s probation condition (loss of visitation/contact) and can enjoin enforcement | Defendants argue Barnett lacks standing because the contested condition is personal to Jackson and defendants lack authority to restore visitation | Court: Barnett lacks Article III standing; he cannot challenge his wife’s probation condition and the relief sought would not be redressed by enjoining the probation officers |
| Redressability of alleged injury | Barnett contends injunctive relief against probation officers will restore his contact/visitation | Defendants note wardens control visitor lists; even if probation condition changed, warden approval is needed | Court: Redress is speculative because probation officers cannot unilaterally place Jackson back on visitor list; warden approval remains necessary |
| Third-party standing (Powers factors) | Barnett implies close relation and practical hindrance justify third-party challenge | Defendants argue Jackson can protect her own interests and Barnett is not the proper party | Court: Third-party standing not satisfied—no showing Jackson cannot litigate her probation condition herself |
| Jurisdictional effect on preliminary injunction | Barnett seeks TRO/PI to stop enforcement pending merits | Defendants moved for summary judgment arguing standing; court treated standing as jurisdictional | Court: Because Barnett lacks standing (jurisdictional defect), court denied injunctive relief and dismissed without prejudice |
Key Cases Cited
- Jones v. Caruso, 569 F.3d 258 (6th Cir. 2009) (factors for preliminary injunction)
- Wilson v. Gordon, 822 F.3d 934 (6th Cir. 2016) (injunctive relief is discretionary)
- Lujan v. Defenders of Wildlife, 504 U.S. 555 (1992) (standing requirements)
- Bennett v. Spear, 520 U.S. 154 (1997) (redressability element of standing)
- Warth v. Seldin, 422 U.S. 490 (1975) (standing and personal stake requirement)
- Powers v. Ohio, 499 U.S. 400 (1991) (third-party standing criteria)
- DaimlerChrysler Corp. v. Cuno, 547 U.S. 332 (2006) (standing as jurisdictional limit)