El-Amin v. District of Columbia
Civil Action No. 2017-0174
| D.D.C. | Jan 27, 2017Background
- Plaintiff is a federal prisoner at USP Inez, Kentucky, proceeding pro se and in forma pauperis.
- He sued the District of Columbia seeking $300,000, alleging the District "deprived" and "punished" his constitutional right to travel by incarcerating him for armed robbery instead of imposing noncustodial sanctions.
- Complaint asserts his right to travel was conditioned and punished by a 30-month prison sentence instead of alternatives (restitution, community service, probation).
- Court conducted an initial review under 28 U.S.C. § 1915A, which requires dismissal of prisoner complaints that fail to state a claim.
- The court treated the claim as implicating the constitutional right to travel and due process, but reasoned that movement restrictions are a necessary incident of incarceration and stem from a valid conviction.
- Court dismissed the case with prejudice because the travel restrictions resulting from imprisonment did not violate the Constitution and the complaint failed to plausibly allege municipal liability.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether incarceration for conviction violated plaintiff's right to travel | Incarceration conditioned and punished his right to travel; should have received noncustodial sanctions | Restriction of movement is a necessary incident of lawful incarceration following conviction | Dismissed — imprisonment following conviction does not violate the right to travel |
| Whether the District of Columbia can be held liable under § 1983 for this claim | District imposed or caused conditioning/punishment of travel rights | Plaintiff failed to allege a municipal custom or policy causing a constitutional violation | Dismissed — no municipal policy/custom alleged to cause violation |
| Whether the complaint meets federal pleading standards | Facts plausibly show constitutional violation | Complaint lacks sufficient factual matter to state a plausible claim under Twombly/Iqbal | Dismissed for failure to state a claim under § 1915A |
| Whether due process protects an absolute right to travel for convicted prisoners/parolees | Travel is an unqualified liberty right | Right to travel is part of liberty but subject to lawful deprivation with due process and is limited for prisoners/parolees | Dismissed — right to travel is not absolute; restrictions incident to custody are lawful |
Key Cases Cited
- Ashcroft v. Iqbal, 556 U.S. 662 (2009) (pleading must state a plausible claim)
- Bell Atl. Corp. v. Twombly, 550 U.S. 544 (2007) (plausibility pleading standard)
- Warren v. District of Columbia, 353 F.3d 36 (D.C. Cir. 2004) (municipal liability requires showing custom or policy caused the violation)
- Collins v. City of Harker Heights, 503 U.S. 115 (1992) (municipal liability principles)
- Baker v. District of Columbia, 326 F.3d 1302 (D.C. Cir. 2003) (municipal liability standard)
- Jones v. Helms, 452 U.S. 412 (1981) (distinguishing travel rights of unqualified citizens from those whose liberty is curtailed)
- Berrigan v. Sigler, 499 F.2d 514 (D.C. Cir. 1974) (right to travel is part of liberty but subject to due process)
- Castaneira v. Potteiger, [citation="621 F. App'x 116"] (3d Cir. 2015) (parole/travel restrictions upheld as within state police power)