Bridges v. Cargor
4:24-cv-12449
| E.D. Mich. | May 29, 2025Background
- Antonio Vallin Bridges is a Michigan prisoner serving concurrent sentences for malicious destruction of property and false pretenses, based on plea convictions from 2015 and 2023.
- Bridges filed a pro se habeas petition under 28 U.S.C. § 2254, claiming a liberty interest in parole due to receiving a "high probability of parole" score and arguing improper denial of parole by the Michigan Parole Board.
- He does not challenge his convictions or sentences, but claims due process violations related to parole procedures and sex offender programming requirements, particularly given a dismissed sex offense charge.
- Bridges has previously filed similar habeas and civil rights actions, all dismissed for failure to state a cognizable habeas claim or constitutional violation.
- The district court conducted an initial screening under Rule 4 of the Habeas Rules and 28 U.S.C. § 2243, ultimately denying relief.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Liberty interest in parole | High probability of parole score gives protected interest | No federal or state right to parole under Michigan law | No protected liberty interest in parole under federal or state law |
| Due process in parole/programming | Due process violated by parole denial, programming requirements | Parole and programming are discretionary, not protected | No due process violation; no protected interest in programs |
| Sex offender classification/program | Requiring sex offender program after sex charges dismissed | Program participation relates to parole eligibility, not right | No habeas claim; claims barred by res judicata |
| Proper vehicle for parole procedure claims | Claims of parole process violations can be raised in habeas | Such claims must be brought as civil rights actions under § 1983 | Must pursue as § 1983 action, not habeas; civil rights claims dismissed |
Key Cases Cited
- Greenholtz v. Inmates of Nebraska Penal & Corr. Complex, 442 U.S. 1 (1979) (no constitutional right to parole under federal law)
- Kentucky Dep’t of Corr. v. Thompson, 490 U.S. 454 (1989) (statutes must create liberty interest for federal due process protection)
- Sweeton v. Brown, 27 F.3d 1162 (6th Cir. 1994) (Michigan parole scheme is discretionary and does not create a liberty interest)
- Crump v. Lafler, 657 F.3d 393 (6th Cir. 2011) (high probability score does not create a parole entitlement)
- Foster v. Booker, 595 F.3d 353 (6th Cir. 2010) (Michigan does not have a protected liberty interest in parole)
- Moody v. Daggett, 429 U.S. 78 (1976) (no due process right in prison job, program, or classification)
- Slack v. McDaniel, 529 U.S. 473 (2000) (standards for certificate of appealability)