Kim Ragland v. Commissioner New Jersey Depart
16-3315
| 3rd Cir. | Nov 30, 2017Background
- Ragland, a state prisoner in New Jersey, sued DOC officials under 42 U.S.C. § 1983 alleging improper deductions from his inmate account that violated his Fourteenth Amendment due process and equal protection rights.
- District Court dismissed claims against one defendant as time-barred and dismissed the equal protection claim; allowed due process claims against remaining defendants to proceed.
- DOC deducted funds from Ragland’s account to satisfy criminal restitution/fines and PLRA filing-fee obligations pursuant to state statutes and the PLRA.
- Ragland alleged deductions exceeded amounts authorized by state law and challenged the calculation under the PLRA as preempted by federal law; he did not claim entitlement to pre-deprivation procedures.
- Defendants moved for summary judgment; District Court granted judgment for defendants concluding the state provided adequate post-deprivation remedies. Ragland appealed.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether the alleged taking required pre-deprivation procedures | Ragland: taking was unauthorized and not random; seeks relief for excess deductions | Defendants: even if deprivation occurred, it was random/unauthorized and state post-deprivation remedies suffice | Court: Post-deprivation remedies (grievance system and NJTCA) are adequate; no relief |
| Whether DOC deducted more than state law allowed | Ragland: deductions exceeded amounts authorized by N.J. statutes and regulations | Defendants: deductions complied with state statutes and DOC policy; plaintiff didn’t dispute his obligations | Court: Ragland’s complaint alleges unauthorized manner but not a substantive overcharge that precludes post-deprivation remedy; no due process violation |
| Whether plaintiff had an adequate post-deprivation remedy | Ragland: argued no post-deprivation hearing | Defendants: prison grievance procedure and NJ Tort Claims Act provide adequate remedies | Court: administrative grievance and NJTCA are adequate even if unsuccessful; suffices under Parratt/Zinermon framework |
| Whether PLRA preempts state statutory collection (calculation) | Ragland: DOC deducted under state statute in a way that conflicted with 28 U.S.C. § 1915(b)(2) | Defendants: DOC applied PLRA first and then state collections; no conflict with federal law | Court: No Supremacy Clause conflict; PLRA not preempted and DOC’s calculations complied with federal statute |
Key Cases Cited
- Higgins v. Beyer, 293 F.3d 683 (3d Cir.) (prisoner has protected property interest in inmate account)
- Zinermon v. Burch, 494 U.S. 113 (1990) (distinction between random/unauthorized deprivations and established-state-procedure takings)
- Parratt v. Taylor, 451 U.S. 527 (1981) (post-deprivation tort remedy can satisfy due process for random unauthorized takings)
- Hudson v. Palmer, 468 U.S. 517 (1984) (post-deprivation tort remedy suffices for random, unauthorized taking)
- Tillman v. Lebanon Cty. Corr. Facility, 221 F.3d 410 (3d Cir.) (prison grievance system can be an adequate post-deprivation remedy)
- Revell v. Port Auth., 598 F.3d 128 (3d Cir.) (discussing adequacy of New Jersey post-deprivation procedures)
- Holman v. Hilton, 712 F.2d 854 (3d Cir.) (NJTCA provides common-law tort actions for inmates)
- Spruill v. Gillis, 372 F.3d 218 (3d Cir.) (standard of review for Rule 12(b)(6) dismissals)
- McGreevy v. Stroup, 413 F.3d 359 (3d Cir.) (standard of review for summary judgment)