COUDRIET v. VARDARO
1:11-cv-00185
W.D. Pa.Jul 24, 2012Background
- Plaintiff Shawn Richard Coudr iet, a state inmate acting pro se, filed a 42 U.S.C. §1983 action on September 1, 2011, naming numerous state and prison officials as defendants.
- Plaintiff seeks substantial monetary damages and declaratory/injunctive relief related to alleged constitutional violations tied to his arrest, conviction for offenses involving minors, and alleged prison-system violations since incarceration.
- The case was administratively closed in March 2012 while counsel was sought; a later filing sought a temporary restraining order against Warden Brian Coleman.
- Judge Baxter, the magistrate judge, recommended denying the TRO as a drastic, extraordinary remedy not typically granted in §1983 actions.
- The recommended denial rests on the four-factor test for preliminary injunctions and the conclusion that Plaintiff’s requested relief is not cognizable in a §1983 action due to Heck v. Humphrey and related authorities.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether the TRO should be granted under the four-factor test | Cou driet contends he faces irreparable harm and a likelihood of success on the merits | Coleman and others resist, arguing no likelihood of success and no irreparable harm, and that relief is improper in §1983 | TRO denied; four-factor test not satisfied for injunction |
| Whether the requested relief is cognizable in a §1983 action | Plaintiff seeks release from confinement as relief in his civil rights complaint | Relief to reduce confinement is not available under §1983 and requires habeas relief | Relief not cognizable; Heck v. Humphrey controls |
| Whether Plaintiff can satisfy the likelihood of irreparable harm and public interest factors | Plaintiff asserts imminent harm from unlawful confinement and public interest in correctional transparency | No irreparable harm shown and no public-interest support for temporary release via §1983 | Insufficient showing of irreparable harm or public interest favoring relief |
Key Cases Cited
- Intel Corp. v. ULSI Sys. Tech., Inc., 995 F.2d 1566 (Fed.Cir. 1993) (preliminary injunction is drastic; four-factor framework)
- Hoxworth v. Blinder, Robinson & Co., Inc., 903 F.2d 186 (3d Cir. 1990) (injunction standards and equity considerations)
- Bimbo Bakeries USA, Inc. v. Botticella, 613 F.3d 102 (3d Cir. 2010) (four-factor test and balance of hardships)
- Miller v. Mitchell, 598 F.3d 139 (3d Cir. 2010) (publication of factors for preliminary injunctions)
- Adams v. Freedom Forge Corp., 204 F.3d 475 (3d Cir. 2000) (likelihood of success and irreparable harm required for injunctive relief)
- Skinner v. Switzer, 131 S. Ct. 1289 (Supreme Court 2011) (limitations on habeas-like relief in civil rights actions)
- Wilkinson v. Dotson, 544 U.S. 74 (Supreme Court 2005) (prisoners cannot obtain release through §1983; must use habeas)
- Heck v. Humphrey, 512 U.S. 477 (Supreme Court 1994) (§1983 relief barred where success would imply invalidity of conviction)