Martin Fountain v. Warden James T Vaughn Correcti
679 F. App'x 117
| 3rd Cir. | 2017Background
- Prisoner Martin E. Fountain was transferred from minimum security to MHU and then to SHU after an administrative classification; he lost his prison job.
- At the time he filed suit, Fountain had not received disciplinary paperwork or results of any investigation related to the transfers.
- Fountain filed a "Motion for Injunction," construed by the district court as a complaint alleging violation of due process and seeking return to minimum security and back pay.
- The district court dismissed the complaint as legally frivolous under 28 U.S.C. § 1915(e)(2)(B)(i) and denied leave to amend; Fountain filed a Rule 59(e) motion for reconsideration six months later, which was denied.
- The Third Circuit lacked jurisdiction to review the original dismissal because Fountain’s Rule 59(e) motion and notice of appeal were untimely; it reviewed only the denial of the Rule 59(e) motion for abuse of discretion.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether transfer/placement in SHU implicated a due process liberty interest | Fountain argued transfer and placement without notice or charges deprived him of a liberty interest | State argued such classification changes are within expected prison conditions and not constitutionally protected | Court held no liberty interest; transfer to more restrictive custody alone does not trigger due process protection |
| Whether Delaware law created a state-created liberty interest | Fountain suggested state procedures or law conferred protected interest | State pointed to Delaware statutes and practice showing no constitutionally protected classification interest | Court held Delaware law did not create a protected liberty interest in classification |
| Whether loss of prison employment amounted to a due process or Eighth Amendment violation | Fountain claimed loss of job deprived him of a liberty interest and was punitive | State argued loss of employment is an ordinary condition of confinement and not a constitutional deprivation | Court held loss of employment did not implicate due process or meet Eighth Amendment severity thresholds |
| Whether the Rule 59(e) motion warranted reconsideration | Fountain reasserted prior arguments and claimed district court should have liberally construed his filings | District court argued motion repeated prior claims and did not present new law, evidence, or clear error | Court held denial of reconsideration was proper; Fountain offered no grounds under Rule 59(e) to warrant relief |
Key Cases Cited
- Neitzke v. Williams, 490 U.S. 319 (1989) (frivolous-pleading standard for § 1915 dismissals)
- Sandin v. Conner, 515 U.S. 472 (1995) (due process protected liberty interests defined by atypical and significant hardship)
- Hewitt v. Helms, 459 U.S. 460 (1983) (limits on judicial oversight of prison administrative decisions)
- Torres v. Fauver, 292 F.3d 141 (3d Cir. 2002) (transfer to more restrictive custody does not necessarily create liberty interest)
- Fraise v. Terhune, 283 F.3d 506 (3d Cir. 2002) (threshold for establishing a protected liberty interest)
- Griffin v. Vaughn, 112 F.3d 703 (3d Cir. 1997) (administrative custody of up to fifteen months not necessarily atypical)
- Max’s Seafood Café v. Quinteros, 176 F.3d 669 (3d Cir. 1999) (standards for Rule 59(e) motions)
- Lizardo v. United States, 619 F.3d 273 (3d Cir. 2010) (untimely Rule 59(e) does not toll appeal deadlines)