David Ruffin v. Superintendent Retreat SCI
689 F. App'x 112
| 3rd Cir. | 2017Background
- Plaintiff David Ruffin, an inmate at SCI-Retreat, filed a § 1983 civil-rights complaint seeking a parole hearing, possible release, and placement in D-Stability programming.
- Ruffin alleged his maximum sentence date was June 14, 2016, but disciplinary sanctions and RHU placement extend his confinement and have prevented a parole hearing.
- He claimed transfer to SCI-Retreat as a D-Stability prisoner but was denied D-Stability services at SCI-Dallas after an incident.
- District Court dismissed the complaint under 28 U.S.C. §§ 1915(e)(2) and 1915A(a) as legally frivolous for failure to state a viable § 1983 claim; Ruffin proceeded in forma pauperis and appealed.
- The Third Circuit reviewed the dismissal de novo and considered whether § 1983 could provide relief for parole/hearing or D-Stability placement.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether § 1983 may be used to obtain a parole hearing or release | Ruffin sought a parole hearing and release via § 1983 | Relief attacking duration/validity of confinement must be pursued in habeas | § 1983 is improper; habeas (§ 2254) is the proper vehicle |
| Whether denial of D-Stability placement violates due process | Ruffin sought placement/rehabilitation programming as due-process right | Prisoners have no constitutional right to particular housing or program placement | No due-process right; claim fails |
| Whether dismissal was appropriate under IFP screening statutes | Ruffin contended his claims merited review and relief | District Court found claims legally frivolous and dismissible under § 1915 standards | Dismissal affirmed as the appeal raised no substantial question |
| Whether appointment of counsel was warranted on appeal | Ruffin requested counsel | No showing of exceptional circumstances to require counsel | Motion for appointment of counsel denied |
Key Cases Cited
- Preiser v. Rodriguez, 411 U.S. 475 (1973) (habeas, not § 1983, is proper remedy for state prisoners attacking validity or duration of confinement)
- Olim v. Wakinekona, 461 U.S. 238 (1983) (no constitutional right to placement in particular prison)
- Sheehan v. Beyer, 51 F.3d 1170 (3d Cir. 1995) (inmate has no liberty interest in specific custody classification or housing assignment)
- Allah v. Seiverling, 229 F.3d 220 (3d Cir. 2000) (standard of review for district court dismissals of in forma pauperis complaints)