Jackson-Allen v. Trevino, 2:15-cv-10561

Plaintiff Derrick Jackson-Allen, a Michigan prisoner, sued MDOC employees Connie Trevino, Lori Engmark, and MDOC Director Daniel Heyns under 42 U.S.C. § 1983, alleging unconstitutional overdetention of 41 months beyond the statutory maximum for his attempted home-invasion conviction.
Jackson-Allen pled guilty in 1999 to attempted home invasion and was sentenced 3–20 years; he contends the statutory maximum was actually 10 years and that he therefore served past the lawful maximum.
He alleges MDOC staff reviewed his file multiple times but failed to detect or correct the sentencing error; he alleges inadequate customs/practices and deliberate indifference, asserting violations of the Fourteenth and Eighth Amendments.
Procedurally, MDOC moved for summary judgment on grounds that Heyns lacked personal involvement, official-capacity claims are barred by sovereign immunity, and defendants are entitled to qualified immunity.
The magistrate judge recommended granting summary judgment: dismissing claims against Heyns for lack of personal involvement, dismissing official-capacity claims under the Eleventh Amendment, and awarding qualified immunity to the individual defendants because no clearly established duty required prison officials to independently audit sentencing orders.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Personal liability of Director Heyns	Heyns is sued as successor MDOC director and therefore liable	Heyns had no personal involvement or direction of the alleged conduct	Dismissed — no allegations of Heyns’ personal participation or encouragement of misconduct
Official-capacity §1983 claims	Official-capacity suits seek relief for systemic MDOC practices	Official-capacity claims are suits against the State and barred by the Eleventh Amendment	Dismissed — sovereign immunity bars official-capacity claims against MDOC employees
Duty to review/correct sentencing errors	MDOC had an obligation to independently review inmate files and correct sentencing errors; failure was deliberate indifference	No clearly established constitutional duty requiring officials to serve as a habeas/sentencing-review team; actions were not objectively unreasonable	Defendants entitled to qualified immunity; plaintiff failed to show a clearly established right
Exhaustion of administrative remedies	Plaintiff says he learned of the error only after parole and so did not have to exhaust while incarcerated	Defendants argued failure to exhaust under the PLRA	Court declined to resolve exhaustion because other grounds disposed of the case

Baker v. McCollan, 443 U.S. 137 (establishes §1983 requires state action and constitutional violation)
Monell v. New York City Dept. of Social Services, 436 U.S. 658 (municipal/supervisory liability cannot rest on respondeat superior)
Rizzo v. Goode, 423 U.S. 362 (requires personal involvement for §1983 supervisory liability)
Saucier v. Katz, 533 U.S. 194 (two-step qualified immunity framework)
Pearson v. Callahan, 555 U.S. 223 (court may decide qualified immunity by addressing clearly established law first)
Emps. of Dep’t of Pub. Health & Welfare v. Dept. of Pub. Health & Welfare, 411 U.S. 279 (Eleventh Amendment bars suits against a state by its own citizens)
Anderson v. Liberty Lobby, 477 U.S. 242 (summary judgment standard for material fact disputes)
Hays v. Jefferson County, 668 F.2d 869 (supervisor liable only if he encouraged or participated in specific misconduct)