Henley v. Smith, 4:13-cv-00050

Background

Pro se plaintiff Jeremy Henley, a pretrial detainee formerly at Union County Jail, sued Jailer Cathy Smith in her official capacity under 42 U.S.C. § 1983 alleging multiple deprivations during February–April 2013.
Alleged injuries: denial of ability to have arresting officer file a criminal complaint; denial of access to legal materials/library visits while pursuing a state habeas petition; involuntary placement in protective custody; denial of a jail work assignment; and denial of recreation on one date.
Plaintiff sought $750,000 in compensatory damages and noted a pending state habeas action (with public defender involvement).
The court screened the complaint under 28 U.S.C. § 1915A and Iqbal/Twombly standards for plausibility and for municipal liability under Monell.
Court treated official-capacity claim against Smith as a suit against Union County and analyzed (1) municipal responsibility and (2) whether constitutional violations occurred.

Issues

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether plaintiff alleged a municipal policy causing denial of access to legal materials	Henley alleged denial stemmed from "departmental policy and procedure" that limited his access to the county library	County/Smith argue no municipal policy caused any constitutional injury; isolated acts, if any, not county policy	Court assumed policy allegation for access-to-courts claim only but dismissed on merits for failure to show actual injury
Whether plaintiff alleged a Monell policy/custom for: inability to file a criminal complaint, protective custody placement, denial of work, denial of recreation	Henley alleges these harms but does not identify any county policy or custom causing them	Smith/County argue these are isolated incidents without municipal policy or custom liability	Court held plaintiff failed to allege a policy/custom linking Union County to these four claims; Monell claim dismissed
Whether denial of access to legal materials violated constitutional right of access to courts	Henley contends lack of library access hindered his state habeas efforts	Defendant argues plaintiff has not shown actual injury to a non-frivolous underlying claim and state proceedings show representation	Court held Henley failed to allege an actual, specific prejudice to an underlying non-frivolous claim; access claim dismissed
Whether official-capacity suit against Smith could proceed absent allegations of Smith’s personal involvement	Henley sued Smith in her official capacity only and alleged no personal acts by Smith	Defendant notes official-capacity claim is equivalent to suit against the county and individual-capacity claims require personal involvement	Court noted no facts against Smith personally; any individual-capacity claim would fail; official-capacity claim dismissed for failure to state a claim

Key Cases Cited

Ashcroft v. Iqbal, 556 U.S. 662 (2009) (pleading must contain factual content to state a plausible claim)
Bell Atlantic Corp. v. Twombly, 550 U.S. 544 (2007) (plausibility standard for complaints)
Monell v. Department of Social Services, 436 U.S. 658 (1978) (municipal liability requires policy or custom causing constitutional violation)
Kentucky v. Graham, 473 U.S. 159 (1985) (official-capacity suit is a suit against the entity)
Bounds v. Smith, 430 U.S. 817 (1977) (recognition of prisoners’ right of access to the courts)
Lewis v. Casey, 518 U.S. 343 (1996) (access-to-courts claim requires showing of actual injury to a non-frivolous underlying claim)
Christopher v. Harbury, 536 U.S. 403 (2002) (access claim must identify the underlying cause of action and lost remedy)
Collins v. City of Harker Heights, 503 U.S. 115 (1992) (elements for municipal liability analysis)