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Joel Holley v. E. Evans
688 F. App'x 451
| 9th Cir. | 2017
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Background

  • Plaintiff Joel Anthony Holley, a California state prisoner, sued under 42 U.S.C. § 1983 alleging deliberate indifference to his safety and procedural due process violations from a disciplinary hearing.
  • Defendants moved for summary judgment; the district court granted it and denied Holley’s requests for additional discovery and a continuance.
  • Holley appealed pro se to the Ninth Circuit; the panel reviewed de novo and could affirm on any record-supported ground.
  • Key factual dispute: whether defendants knew of and consciously disregarded an excessive risk to Holley’s safety; related procedural dispute concerned alleged defects in a prison disciplinary proceeding.
  • Procedural posture: appeal from summary judgment and denial of Rule 56(f)-type discovery/continuance requests.

Issues

Issue Plaintiff's Argument Defendant's Argument Held
Deliberate indifference to safety Holley contended defendants knew of a serious risk to his safety and ignored it Defendants argued no evidence they were subjectively aware of and disregarded an excessive risk Affirmed for defendants; Holley failed to raise a genuine dispute on subjective knowledge/disregard (Farmer standard)
Due process claim that would invalidate disciplinary finding Holley argued hearing violated due process, implying relief Defendants argued such a claim is barred unless disciplinary sentence has been invalidated (Heck) Affirmed: Heck/Edwards bar applies because Holley didn’t show disciplinary sentence invalidated
Due process claim not necessarily implying invalidity Holley argued hearing procedures independently violated due process Defendants argued no protected liberty interest in alleged procedural errors Affirmed: Holley failed to show a cognizable liberty interest entitled to procedural protections
Denial of further discovery / continuance Holley argued additional discovery was needed to oppose summary judgment Defendants argued district court properly found additional discovery unnecessary Affirmed: district court did not abuse discretion in denying discovery/continuance requests

Key Cases Cited

  • Toguchi v. Chung, 391 F.3d 1051 (9th Cir. 2004) (standard of review for Eighth Amendment deliberate indifference claims)
  • Farmer v. Brennan, 511 U.S. 825 (1994) (prison official liable only if subjectively aware of substantial risk)
  • Johnson v. Riverside Healthcare Sys., LP, 534 F.3d 1116 (9th Cir. 2008) (appellate court may affirm on any ground supported by the record)
  • Heck v. Humphrey, 512 U.S. 477 (1994) (actions that would necessarily imply invalidity of conviction are barred until conviction is invalidated)
  • Edwards v. Balisok, 520 F.3d 641 (Note: actual opinion is Edwards v. Balisok, 520 U.S. 641) (1997) (Heck extended to prison disciplinary proceedings affecting good-time credits)
  • Serrano v. Francis, 345 F.3d 1071 (9th Cir. 2003) (due process protections attach only when disciplinary action implicates a protected liberty interest)
  • Mann v. Adams, 855 F.2d 639 (9th Cir. 1988) (no constitutional entitlement to a prison grievance procedure)
  • Blough v. Holland Realty, Inc., 574 F.3d 1084 (9th Cir. 2009) (denial of continuance for discovery is proper when additional discovery would not affect summary judgment outcome)
  • Tatum v. City & County of San Francisco, 441 F.3d 1090 (9th Cir. 2006) (standards for obtaining additional discovery to oppose summary judgment)
Read the full case

Case Details

Case Name: Joel Holley v. E. Evans
Court Name: Court of Appeals for the Ninth Circuit
Date Published: Apr 19, 2017
Citation: 688 F. App'x 451
Docket Number: 16-16012
Court Abbreviation: 9th Cir.