Hill v. Henderson, 3:17-cv-00825

Plaintiff Tyrice Hill, a pro se prisoner at Toledo Correctional Institution, sued under 42 U.S.C. § 1983 against Deputy Warden Kimberly Henderson, librarian Rose Shaddy, and Institutional Inspector Dereic Burkhart for denial of access to courts, retaliation, and Eighth Amendment cruel and unusual punishment.
Hill alleges inmates get 4½ hours/week in the law library, scheduling conflicts with religious services/visitation/recreation reduce his usable time, and library resources/staff are inadequate.
Hill alleges Shaddy repeatedly removed him from the law library and filed false conduct reports (including a sexual-misconduct charge later dismissed as unfounded by the Rules Infraction Board).
Hill filed informal complaints and grievances to Henderson and Burkhart; he contends grievances were denied and that the defendants’ actions impeded his ability to obtain a transcript and pursue a resentencing appeal.
The Court screened the complaint under 28 U.S.C. § 1915(e) and dismissed claims against Henderson and Burkhart and Hill’s access-to-courts and Eighth Amendment claims; it allowed the retaliation claim against Shaddy to proceed provisionally while ordering production of grievance records to assess exhaustion.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Denial of access to courts	Hill says limited library time, scheduling conflicts, inadequate resources prevented necessary research and caused procedural harm (denied transcript/motion)	Defendants contend library schedule and resources do not show concrete injury or denial of access	Dismissed — Hill failed to allege a nonfrivolous underlying claim or actual injury required by Lewis/Christopher
Eighth Amendment (conditions)	Limited library access and removals constitute cruel and unusual punishment	Defendants say allegations amount to inconveniences, not serious deprivations	Dismissed — allegations describe routine inconveniences, not objective serious conditions or deliberate indifference
Retaliation (First Amendment)	Shaddy retaliated by issuing false conduct reports after Hill filed grievances and complaints	Defendants dispute causal link and argue conduct may predate grievances; exhaustion unclear	Survives initial screening — retaliation claim against Shaddy permitted to proceed pending review of grievance exhaustion
Liability for Henderson and Burkhart	Hill seeks relief from supervisors/officials who denied grievances and managed library	Defendants argue denial of grievances alone does not create § 1983 liability	Dismissed — denying grievances alone is not sufficient for § 1983 liability (Shehee)

Lewis v. Casey, 518 U.S. 343 (1996) (to state an access-to-courts claim plaintiff must show actual injury to a nonfrivolous underlying claim)
Christopher v. Harbury, 536 U.S. 403 (2002) (access-to-courts claim requires plausible allegations about the underlying claim and injury)
Bounds v. Smith, 430 U.S. 817 (1977) (prisoners entitled to adequate law libraries or assistance, but not an abstract right to a library)
Wilson v. Seiter, 501 U.S. 294 (1991) (framework for Eighth Amendment conditions-of-confinement claims requiring objective and subjective elements)
Farmer v. Brennan, 511 U.S. 825 (1994) (deliberate indifference standard for Eighth Amendment liability)
Hudson v. McMillian, 503 U.S. 1 (1992) (Eighth Amendment requires extreme deprivations; routine discomforts insufficient)
Shehee v. Luttrell, 199 F.3d 295 (6th Cir. 1999) (denial of grievances is not enough for § 1983 supervisory liability)
Thaddeus-X v. Blatter, 175 F.3d 378 (6th Cir. 1999) (elements of prisoner First Amendment retaliation claim)
Thomas v. Eby, 481 F.3d 434 (6th Cir. 2007) (false misconduct reports can constitute retaliation)
Scott v. Churchill, 377 F.3d 565 (6th Cir. 2004) (retaliatory false reports actionable under First Amendment)