Clarence Schreane v. Seana
506 F. App'x 120
3rd Cir.2012Background
- Schreane, a federal inmate, appeals denial of his motion for reconsideration of a district court order dismissing his second amended Bivens complaint with prejudice.
- He alleged Code 205 misconducts based on sexual conduct, sought to view surveillance videotape, and claimed retaliation and due process violations by several officers.
- He also alleged a planted object during another Code 205 incident, denied video access, and claimed SHU confinement and lost good-time credits.
- He asserted First Amendment rights to religious oils, claiming officers failed to secure the oils; he sought redress for these disciplinary matters and loss of credits.
- The district court dismissed multiple claims with prejudice and allowed an equal protection claim to proceed only if amended; Schreane filed a second amended complaint and the district court again dismissed with prejudice; Schreane moved for reconsideration, which was denied, leading to the current appeal.
- The court reviews the district court’s dismissal de novo and the motion for reconsideration for abuse of discretion; Heck v. Humphrey and Edwards v. Balisok govern prison-discipline-related claims; the court modifies the dismissal to be without prejudice for due process claims.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether Fifth Amendment due process claims are barred by Heck/Edwards. | Schreane argues the dispositions violated due process. | Schreane’s claims challenge disciplinary outcomes; Heck/Edwards apply. | Edwards dismissal without prejudice; Heck bar not applicable. |
| Whether Donohue’s negligence violated the First Amendment rights to free exercise of religion. | Schreane asserts Donohue failed to secure oils. | Isolated negligence not a First Amendment violation. | First Amendment claim properly dismissed. |
| Whether Eighth Amendment claims regarding SHU placement and loss of good-time credits state a viable claim. | Schreane alleges cruel and unusual punishment. | Showed no substantial deprivation or deliberate indifference. | Eighth Amendment claim not stated. |
| Whether Schreane adequately pleaded an equal protection claim. | Schreane alleges discrimination as an African-American inmate. | No evidence of disparate treatment compared to similarly situated inmates. | Equal protection claim failed. |
Key Cases Cited
- Ashcroft v. Iqbal, 556 U.S. 662 (U.S. 2009) (pleading standard; plausibility requirement)
- Twombly v. Bell Atlantic Corp., 550 U.S. 544 (U.S. 2007) (pleading must state plausible claim)
- Heck v. Humphrey, 512 U.S. 477 (U.S. 1994) (bar on §1983/Bivens claims if success would invalidate conviction/sentence)
- Edwards v. Balisok, 520 U.S. 641 (U.S. 1997) (bar on disciplinary sanctions claims; habeas/§2241 alternative)
- Wilkinson v. Dotson, 544 U.S. 74 (U.S. 2005) (prospective relief not allowed to affect custody/sentence)