Miller v. Metzger
1:19-cv-01794
| D. Del. | Mar 7, 2022Background
- John Miller, a pro se prisoner, asked the court to reconsider and amend an earlier opinion that dismissed with prejudice his constitutional claims against prison officials and to make factual findings.
- Miller alleged retaliation for acting as an informant and a due-process violation based on brief isolation and assignment to the Security Housing Unit (SHU).
- The district court dismissed his retaliation claim because (1) the complaint did not allege that his informant activities were constitutionally protected and (2) the complaint did not plead causation linking those activities to the alleged retaliation.
- The court dismissed the due-process claim because Miller failed to allege that his disciplinary confinement imposed an "atypical and significant hardship" sufficient to create a protected liberty interest.
- Miller pointed to prior PLRA prescreening that found his initial complaint "cognizable," sought deletion of a reference to an earlier prison uprising, and asked the court to make factual findings about guilt; the court denied all requests.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Motion to reconsider dismissal | Miller: court erred and must reconsider under Rule 59(e) (change in law, new evidence, or clear error) | Court: Miller did not show change in law, new evidence, or clear legal error | Denied — high standard not met |
| Retaliation claim | Miller: punishment was retaliation for cooperating as an informant | Prison officials: informant activity not constitutionally protected; complaint lacks causation | Denied — activities not protected; complaint fails to plead causation |
| Effect of PLRA prescreening | Miller: prior screening finding barred later dismissal | Prison officials: prescreening does not preclude dismissal on later review | Denied — prescreening does not prevent dismissal |
| Due-process (liberty interest) | Miller: SHU assignment and isolation were atypical because imposed for cooperation and disciplinary process was corrupt | Prison officials: conditions/duration not atypical; no protected liberty interest; therefore no process due | Denied — failed to allege "atypical and significant hardship" or punishment for exercising constitutional right |
| Motion to amend factual description | Miller: remove wording tying case to an earlier uprising | Court: phrasing paraphrased Miller's submissions and was not outcome-determinative | Denied — no change in holdings even if wording clarified |
| Motion for factual findings at dismissal stage | Miller: court should rule on whether evidence supported guilt | Court: motions to dismiss accept complaint facts as true; factual findings reserved for later stages | Denied — no factual findings at dismissal stage |
Key Cases Cited
- Lazaridis v. Wehmer, 591 F.3d 666 (3d Cir. 2010) (standard for reconsideration under Rule 59(e))
- Pension Benefit Guar. Corp. v. White Consol. Indus., Inc., 998 F.2d 1192 (3d Cir. 1993) (limits on considering facts outside the complaint on a motion to dismiss)
- Grayson v. Mayview State Hosp., 293 F.3d 103 (3d Cir. 2002) (prescreening under PLRA does not bar later dismissal)
- Sandin v. Conner, 515 U.S. 472 (1995) (protected liberty interest requires atypical and significant hardship)
- Burns v. Pa. Dep’t of Corr., 642 F.3d 163 (3d Cir. 2011) (prison disciplinary punishments usually do not implicate protected liberty interests)
- Mitchell v. Horn, 318 F.3d 523 (3d Cir. 2003) (duration and conditions determine atypicality; no process owed if no protected liberty interest)
- Smith v. Mensinger, 293 F.3d 641 (3d Cir. 2002) (alleged punishment must plausibly be for exercising a constitutional right)
- Estelle v. Gamble, 429 U.S. 97 (1976) (pro se complaints held to less stringent standards)
- Brodzki v. Fox Broad. Co., 868 F. Supp. 2d 386 (D. Del. 2012) (on motions to dismiss, courts accept all factual allegations in the complaint as true)