Gray v. GEO Group Inc Lawton Correctional Facility, 5:17-cv-00137

Background

Plaintiff Fredrick Rideout Gray, Jr., a pro se, in forma pauperis prisoner at Lawton Correctional Facility (LCF), sued over 23 defendants (GEO Group, LCF and Oklahoma DOC officials) under 42 U.S.C. § 1983 alleging inadequate medical and mental-health care, ignored grievances, denial of program access, false/retaliatory misconduct reports, an unconstitutional 10:00 p.m. lights-out policy, and failures to protect from inmate assault.
He sought money damages, injunctive relief (transfer and medical care), declaratory relief, and expungement of disciplinary convictions.
The magistrate judge conducted screening under 28 U.S.C. §§ 1915A and 1915(e)(2) and applied the Iqbal/Twombly plausibility standard while construing pro se allegations liberally.
The report recommends dismissal of all federal claims: some dismissed with prejudice (no amendment possible) and others without prejudice (insufficient factual detail). Official-capacity damage claims against DOC employees and all state-law claims were recommended dismissed without prejudice.
The magistrate also recommended denial of appointed counsel, finding the claims nonmeritorious and not legally/factually complex.

Issues

Issue	Plaintiff's Argument	Defendant's Argument	Held
Eleventh Amendment immunity for official-capacity damage claims	Gray seeks monetary relief against DOC officials in their official capacities	DOC officials are immune under the Eleventh Amendment; Oklahoma has not waived immunity for § 1983 in federal court	Dismiss official-capacity damage claims without prejudice (Eleventh Amendment bars them)
Eighth Amendment deliberate indifference to medical/mental-health needs	Gray alleges denial/delay of meds, inadequate mental-health care, untreated knee/neck pain and other medical problems	Defendants argue allegations are conclusory, fail to plead serious medical need or that officials knew and disregarded substantial risk	Dismiss without prejudice for failure to plead objective and subjective elements sufficiently
Claims based on unanswered/returned grievances (due process / First Amendment)	Gray alleges officials ignored or mishandled grievances violating due process and free speech/petition rights	There is no constitutional right to a grievance process; denial of grievances does not itself violate First Amendment or due process	Dismiss with prejudice (no amendment can cure)
Denial of access to prison programs (due process / equal protection)	Gray claims officials denied work/training programs and treated him unfairly	Participation in programs is not a protected liberty interest; no facts alleging disparate treatment versus similarly situated inmates	Due process claim dismissed with prejudice; equal protection claim dismissed without prejudice (insufficient comparator facts)
Lights-out policy (Eighth Amendment)	Gray contends 10:00 p.m. lights-out prevents writing grievances/letters and is unconstitutional	Defendants note no constitutional right to continuous cell lights; restrictive conditions are not per se cruel and unusual	Dismiss with prejudice (frivolous; no constitutional violation)
False/"bogus" misconduct reports and retaliation	Gray alleges malicious false reports and that one misconduct (Juarez) was retaliation for grievances	False-report claims alone do not state a constitutional claim absent retaliation or other cognizable injury; retaliation claim lacks specific facts (timing, motive, causation)	False-report claims dismissed with prejudice (where not retaliation); Juarez retaliation claim dismissed without prejudice (insufficient factual detail)
Failure to protect from inmate assault	Gray alleges threats/assaults by mentally ill/sexual deviant cellmate and that officials failed to protect him	Defendants contend allegations are conclusory and lack facts showing officials knew of and disregarded substantial risk	Dismiss without prejudice for failure to plead subjective knowledge and personal involvement

Key Cases Cited

Farmer v. Brennan, 511 U.S. 825 (establishes deliberate indifference standard for prison conditions and failure to protect)
Ashcroft v. Iqbal, 556 U.S. 662 (pleading standard; conclusory allegations insufficient)
Kentucky v. Graham, 473 U.S. 159 (official-capacity suit is suit against the state; Eleventh Amendment implications)
Hudson v. Palmer, 468 U.S. 517 (prison officials must provide humane conditions; cited for Eighth Amendment context)
Heck v. Humphrey, 512 U.S. 477 (limits § 1983 claims that would imply invalidity of convictions/disciplinary findings)
Edwards v. Balisok, 520 U.S. 641 (extends Heck to prison disciplinary proceedings)
Sealock v. Colorado, 218 F.3d 1205 (10th Cir.; deliberate indifference requires objective and subjective components)
Kay v. Bemis, 500 F.3d 1214 (10th Cir.; accept pro se allegations as true but apply plausibility review)
Mann v. Boatright, 477 F.3d 1140 (8th Cir. procedural pleading guidance; used for Rule 8 notice requirements)