804 F. Supp. 2d 134
W.D.N.Y.2011Background
- Plaintiff Junior Collins, an inmate, filed 42 U.S.C. § 1983 action alleging multiple constitutional violations at Five Points Correctional Facility related to incidents in 2008–2009.
- Plaintiff named four DOCS employees as defendants: Cordway, Williams, Ferguson, and Fischer; all moved to dismiss under Rule 12(b)(6).
- Plaintiff was placed in administrative keeplock on Oct. 5, 2008, and found guilty of a rule violation on Oct. 14, 2008, resulting in SHU confinement and loss of privileges and good time.
- Sentence was originally twelve months in SHU, later modified December 18, 2008 to six months; a later administrative reversal occurred in Oct. 2009.
- Plaintiff alleges Cordway issued a false disciplinary infraction and placement in keeplock; Ferguson allegedly biased and restrictive during the hearing; Williams allegedly testified falsely; Fischer allegedly involvement via supervisory review and reversal decisions.
- Plaintiff also alleges unsanitary cells, lack of meals, denied medical attention for a prostate condition, and denial of medications, attributed to unspecified state officials.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Eleventh Amendment official-capacities bar? | Plaintiff sues defendants in their official capacities for monetary damages. | Official-capacity claims are treated as claims against the state, barred by Eleventh Amendment. | Dismissed official-capacity claims against all defendants. |
| Eighth Amendment conditions and medical denial in SHU? | Conditions of confinement and denial of medical care in SHU violated Eighth Amendment. | No proof tying defendants to those SHU conditions or medical denial. | Dismissed Eighth Amendment claims. |
| Due process against Cordway for false infraction and keeplock? | Cordway’s actions violated due process via false misbehavior report and keeplock. | Noncompliance with state testing procedures does not establish federal due process violation; no independent harm shown. | Dismissed due process claim against Cordway. |
| Due process against Williams for false testimony at hearing? | Williams lied to bolster Cordway’s testimony, violating due process. | There is no constitutional right to be free from false testimony at disciplinary hearings. | Claim against Williams dismissed. |
| Personal involvement of Ferguson and Fischer; qualified immunity? | Ferguson denied evidence/witnesses; Fischer reversed then affirmed; both personally involved. | Qualified immunity and lack of complete record; cannot determine personal involvement at pleadings stage. | Ferguson claim survives, Fischer claim survives for now; qualified immunity denied as premature. |
Key Cases Cited
- Hill v. Hill, 472 U.S. 445 (U.S. Supreme Court, 1985) (due process review in prison disciplinary cases requires some evidence)
- Boddie v. Schnieder, 105 F.3d 857 (2d Cir. 1997) (no constitutional right to be free from false misbehavior reports absent retaliation)