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