Grantham v. Sexton, 1:22-cv-00059

Background

Plaintiff James Grantham, a pretrial detainee at Allegan County Jail, was arraigned on Jan. 10, 2022 and waived appointed counsel.
Grantham requested access to a functional law library, legal research assistance, writing materials, and copies to prepare motions for a Jan. 28, 2022 court date.
Defendants are jail officials (Lieutenant Charity Cummins; Sergeants John Sexton and Jeff LaBrie; Correctional Officers Cory Dine and Alex Madejczyk), who allegedly denied library access and free copies and enforced a policy against self-representation resources.
Grantham filed a § 1983 action seeking injunctive relief (library, materials, copies) and damages; he consented to proceed before a magistrate judge.
The court conducted preliminary review under the PLRA (28 U.S.C. §§ 1915(e)(2), 1915A(b)) and dismissed the complaint for failure to state a claim.

Issues

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether denial of law library/resources violated right of access to courts	Grantham: denial prevented him from preparing his criminal defense and civil claims	Defendants: state need not provide library access when defendant waives counsel; no actionable interference	Dismissed — under Sixth Circuit precedent a pro se pretrial detainee who waived counsel is not constitutionally entitled to law library access; no actionable actual injury for his civil claim either
Whether refusal to provide free photocopies violated right of access	Grantham: defendants refused to make copies of his filings, impeding access	Defendants: no constitutional right to unlimited free photocopying; no actual injury alleged	Dismissed — prisoners have no right to unlimited free photocopies and Grantham alleged no actual injury
Whether magistrate judge could screen/schedule without defendants’ consent	Grantham consented to magistrate jurisdiction; screening occurs before service	Defendants not yet served; argument exists in other circuits that all parties must consent	Magistrate could perform PLRA screening because defendants were not yet served and thus not parties required to consent (court noted contrary authority/circuit split in footnote)

Key Cases Cited

Bounds v. Smith, 430 U.S. 817 (1977) (states must provide law libraries or alternatives to protect prisoners’ right of access to courts)
Lewis v. Casey, 518 U.S. 343 (1996) (right of access requires showing of actual injury to nonfrivolous claim)
Christopher v. Harbury, 536 U.S. 403 (2002) (access claim must plead the underlying cause of action and lost remedy)
United States v. Smith, 907 F.2d 42 (6th Cir. 1990) (knowing waiver of counsel relinquishes entitlement to law library)
United States v. Sammons, 918 F.2d 592 (6th Cir. 1990) (state not required to provide law library to self-represented criminal defendants)
Thaddeus-X v. Blatter, 175 F.3d 378 (6th Cir. 1999) (access to courts covers direct appeals, habeas, and civil rights claims)
Knop v. Johnson, 977 F.2d 996 (6th Cir. 1992) (prison officials may not erect barriers that impede access to courts)
Bell Atl. Corp. v. Twombly, 550 U.S. 544 (2007) (pleading must state a plausible claim)
Ashcroft v. Iqbal, 556 U.S. 662 (2009) (pleading standards apply to pro se complaints)
Haines v. Kerner, 404 U.S. 519 (1972) (pro se complaints construed liberally)
Denton v. Hernandez, 504 U.S. 25 (1992) (frivolousness standard)
West v. Atkins, 487 U.S. 42 (1988) (§ 1983 elements require state action and constitutional violation)
Murphy Bros. v. Michetti Pipe Stringing, Inc., 526 U.S. 344 (1999) (service of process is fundamental to imposing litigation obligations)
McGore v. Wrigglesworth, 114 F.3d 601 (6th Cir. 1997) (PLRA screening procedures)
Coppedge v. United States, 369 U.S. 438 (1962) (good-faith standard for appeals)