Daniel Matthews v. Debra Hascall
19-35949
| 9th Cir. | Jun 22, 2021Background
- Plaintiff Daniel Matthews, an Oregon inmate, sued Eastern Oregon Correctional Institution (EOCI) officials under 42 U.S.C. § 1983 raising claims including denial of access to courts, retaliation by the library coordinator, unconstitutional application of disobedience/disrespect rules, Fourth and Sixth Amendment violations, and procedural due process violations from a disciplinary hearing and property loss.
- Matthews was charged for printing/copying, was required to comply with library rules, and was asked to delete an unauthorized document and wait outside the law library; he resisted those orders and was argumentative in front of other inmates.
- He alleged the library coordinator’s actions chilled his First Amendment rights and interfered with his ability to pursue legal actions, but produced no evidence of actual injury to pending or contemplated litigation.
- Matthews challenged the disciplinary proceedings and claimed deprivation of employment, education, housing, and property; he sought additional discovery at the district court.
- The district court granted summary judgment for EOCI officials; Matthews appealed and the Ninth Circuit affirmed in a unanimous, unpublished decision without oral argument.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Access to courts | Library rules, printing charges, and coordinator’s conduct prevented Matthews from pursuing legal claims | Matthews suffered no actual injury and could pursue legal action | Affirmed: no actual-injury shown, claim fails (access-to-courts standard) |
| Retaliation / First Amendment | Coordinator’s enforcement of rules and charging for copies was retaliatory and chilled speech | Actions were routine rule enforcement and advanced penological interests | Affirmed: no evidence of chilling an ordinary person or lack of penological justification |
| Constitutionality of disobedience & disrespect rules (Turner claim) | Rules were applied unconstitutionally to Matthews | Rules are reasonably related to legitimate penological interests given his refusals and conduct | Affirmed: rules constitutional as applied to Matthews |
| Fourth & Sixth Amendments | Coordinator’s scrutiny of documents and related procedures violated Fourth and Sixth Amendment rights | Scrutiny was permissible to enforce library rules; Sixth Amendment protections don’t apply to prison disciplinary context | Affirmed: no Fourth Amendment violation; Sixth Amendment inapplicable |
| Procedural due process (discipline, liberty interests, property loss) | Matthews had protected liberty interests and inadequate process; property loss violated due process | No protected liberty interests in alleged privileges; disciplinary findings supported by evidence; state provides adequate post-deprivation remedy for property loss | Affirmed: Sandin/Hill standards not met; adequate post-deprivation remedies exist |
| Motion to compel discovery | Additional discovery was necessary to oppose summary judgment | Additional discovery would not affect issues decided on summary judgment | Affirmed denial as moot: extra discovery would not change outcome |
Key Cases Cited
- Lewis v. Casey, 518 U.S. 343 (actual-injury requirement for access-to-courts claims)
- Rhodes v. Robinson, 408 F.3d 559 (retaliation standard in prison context; adverse action and chilling inquiry)
- Turner v. Safley, 482 U.S. 78 (prison regulations valid if reasonably related to legitimate penological interests)
- Hudson v. Palmer, 468 U.S. 517 (limitations on Fourth Amendment protections in prisons and adequacy of post-deprivation remedies)
- Wolff v. McDonnell, 418 U.S. 539 (prison disciplinary proceedings are not criminal prosecutions; full criminal procedural rights not applicable)
- Sandin v. Conner, 515 U.S. 472 (limiting protected liberty interests arising from prison policies)
- Superintendent, Mass. Corr. Inst. v. Hill, 472 U.S. 445 (evidentiary standard for prison disciplinary findings)
- Johnson v. Moore, 948 F.2d 517 (prison law library management and related restrictions)
- Dilley v. Gunn, 64 F.3d 1365 (requirement to show actual injury for access-to-courts claims)
- Franklin v. Oregon, 662 F.2d 1337 (state post-deprivation remedies can satisfy due process)