Codrington v. Vannoy
3:19-cv-00434
| M.D. La. | Dec 11, 2019Background
- Plaintiff Edwin Codrington, an LSP (Angola) inmate, filed a pro se § 1983 suit against several prison officials alleging a falsified disciplinary report that placed him in administrative segregation.
- He also complained of dangerous conditions in administrative segregation and alleged he was stabbed there after three days.
- The disciplinary charge was later dismissed after appeals and rehearings.
- Plaintiff seeks monetary and injunctive relief and requested appointment of counsel.
- The Magistrate Judge reviewed the complaint under 28 U.S.C. §§ 1915(e) and 1915A and recommended dismissal for failure to state a claim and decline of supplemental jurisdiction over any state-law claims.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| False disciplinary report / procedural due process | Codrington argues the report was falsified and caused segregation punishment | False reports alone do not create a constitutional violation; segregation here was not an atypical, significant deprivation | Dismissed — false reports and placement in administrative segregation do not, by themselves, state a due process claim (Sandin) |
| Investigation/handling of disciplinary proceedings | Codrington contends proceedings were mishandled despite appeals | There is no constitutional right to a favorable investigation or outcome of grievances/discipline | Dismissed — no due process right to investigation or favorable resolution (Geiger) |
| Conditions of administrative segregation / Eighth Amendment | Alleged understaffing and assault; segregation is dangerous | General allegations of prison dangerousness are insufficient; must show totality comparable to extreme conditions cases | Dismissed — pleaded conditions fall far short of the constitutional standard (Williams v. Edwards standard) |
| Failure to protect re: inmate assault | Defendants failed to protect Codrington from known risks leading to stabbing | Liability requires deliberate indifference: awareness of a specific, substantial risk and failure to take reasonable steps | Dismissed — plaintiff did not allege facts showing officials had specific knowledge of risk or deliberate indifference (Farmer) |
| Supplemental jurisdiction over state-law claims | Plaintiff seeks supplemental jurisdiction for any state claims | Court may decline if federal claims are dismissed | Court should decline supplemental jurisdiction and dismiss state claims without prejudice |
Key Cases Cited
- Denton v. Hernandez, 504 U.S. 25 (1992) (standard for dismissing frivolous in forma pauperis suits)
- Neitzke v. Williams, 490 U.S. 319 (1989) (frivolous-complaint doctrine)
- Collins v. King, 743 F.2d 248 (5th Cir. 1984) (false disciplinary reports alone not a constitutional violation)
- Sandin v. Conner, 515 U.S. 472 (1995) (liberty-interest test for prison disciplinary sanctions)
- Geiger v. Jowers, 404 F.3d 371 (5th Cir. 2005) (no due-process right to favorable resolution of grievances)
- Williams v. Edwards, 547 F.2d 1206 (5th Cir. 1977) (identifying extreme totality-of-conditions needed to establish Eighth Amendment violation)
- Farmer v. Brennan, 511 U.S. 825 (1994) (deliberate indifference standard for failure-to-protect claims)