CORBETT v. LAGANA
2:11-cv-06560
D.N.J.Jul 19, 2012Background
- Plaintiff is a state prisoner confined at Northern State Prison, New Jersey.
- He alleges from December 8, 2010 to January 6, 2011 he was housed in an inhumane area without relief and deprived of proper linens, clothes, and cosmetics, and his remedies went unanswered.
- He further alleges on March 11, 2011 he was placed in a cell as personal punishment causing mental distress, with remedies again unanswered.
- Plaintiff seeks transfer to a different unit and monetary relief.
- The court screened the complaint sua sponte under 28 U.S.C. §1915(e)(2)(B) and §1915A, evaluating whether the claims are frivolous, malicious, or fail to state a claim.
- The court dismissed all claims for failure to state a claim, without prejudice, concluding there was no cognizable §1983 or Eighth Amendment violation based on housing and confinement conditions.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether plaintiff has a protectable liberty interest in housing assignment. | Plaintiff asserts a housing placement liberty interest. | Prison housing decisions fall within prison administrators’ expertise; no liberty interest in a particular wing or assignment. | Plaintiff’s housing claim dismissed; no liberty interest in housing assignment. |
| Whether the conditions of confinement alleged state an Eighth Amendment violation. | Alleged denial of heat, linens, clothes, cosmetics constitutes cruel and unusual punishment. | Deprivations were not an extreme or prolonged hardship; not sufficiently grave. | Eighth Amendment claim dismissed; conditions described not a serious deprivation. |
Key Cases Cited
- Hewitt v. Helms, 459 U.S. 460 (1983) (no liberty interest in remaining in general population; housing decisions within administrators’ expertise)
- Sandin v. Connor, 515 U.S. 472 (1995) (discretionary confinement must be atypical and significant hardship to create liberty interest)
- Montanye v. Haymes, 427 U.S. 236 (1976) (liberty interests arise only if confinement conditions violate constitution or statutory protections)
- Rhodes v. Chapman, 452 U.S. 337 (1981) (deprivations must deprive inmate of minimal civilized necessities to support Eighth Amendment claim)
- Farmer v. Brennan, 511 U.S. 825 (1994) (deliberate indifference standard for Eighth Amendment conditions of confinement)
- Wilson v. Seiter, 501 U.S. 294 (1991) (requires both objective and subjective components for Eighth Amendment claim, with deliberate indifference)