Mustafa-El Ajala v. William Swiekatowski
673 F. App'x 570
| 7th Cir. | 2017Background
- In 2007 Ajala (Muslim, black) circulated a petition at Green Bay Correctional Institution that officials deemed inflammatory; investigations revealed a planned riot and improvised weapons.
- Lieutenant William Swiekatowski issued a conduct report charging Ajala with conspiring to incite a riot and battery; three informants identified Ajala and other corroborating evidence existed.
- Seven inmates were charged with the most serious offenses; all seven were Muslim, six were black and one white; Ajala received one year in disciplinary segregation.
- Ajala exhausted prison appeals and sought certiorari in state court, which rejected his procedural-due-process and bias claims regarding the disciplinary hearing officers.
- Ajala sued under 42 U.S.C. § 1983 alleging race- and religion-based discrimination by Swiekatowski and denial of procedural due process by hearing officers; district court granted summary judgment on due process (Rooker–Feldman) and a jury returned against Ajala on discrimination.
- Ajala’s post-trial motion for a new trial was denied; he appealed, arguing the verdict was against the weight of the evidence, instructional error, denial of witnesses, and improper summary judgment dismissal of his due-process claim.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether the jury verdict was against the manifest weight of the evidence | Ajala: evidence showed Swiekatowski selectively disciplined Muslims/blacks; witnesses contradicted Swiekatowski | Swiekatowski: discipline based on corroborated informant evidence and prison rules forbidding reliance on uncorroborated informants | Affirmed — Ajala did not meet the high standard; jury rationally credited Swiekatowski’s explanations (Saathoff standard) |
| Whether the court should have given burden-shifting instruction on discrimination claims | Ajala: court should have instructed that defendant must prove nondiscriminatory reasons were sound and narrowly tailored | Court/defendant: plaintiff first had to prove discriminatory motive; jury found he did not | Affirmed — no prejudice because jury found Ajala failed to show discrim. motive (so burden-shifting never triggered) |
| Whether denial of transport (and video) for two inmate witnesses violated right to present a defense | Ajala: witnesses would corroborate racial/religious labeling and signatories; video option not requested below | Defendants: transport posed security costs; testimony cumulative of facts Ajala personally knew | Affirmed — argument waived for video; testimony cumulative and would not change outcome |
| Whether Rooker–Feldman barred federal review of Ajala’s procedural due-process claim | Ajala: state proceedings had ‘‘limitations’’ that prevented full challenge to hearing officers’ impartiality | Defendants: state court actually considered and rejected bias/due-process arguments; Rooker–Feldman applies | Affirmed — Rooker–Feldman bars relitigation of the state-court judgment on due process |
Key Cases Cited
- Saathoff v. Davis, 826 F.3d 925 (7th Cir.) (standard for overturning a jury verdict as against the manifest weight of the evidence)
- Smith v. Wilson, 705 F.3d 674 (7th Cir.) (burden-shifting framework for constitutional discrimination claims)
- Bond v. Atkinson, 728 F.3d 690 (7th Cir.) (plaintiff must show discriminatory motive before defendant bears burden to justify conduct)
- Viramontes v. City of Chicago, 840 F.3d 423 (7th Cir.) (prejudice requirement for instructional error)
- Sykes v. Cook Cty. Circuit Court Prob. Div., 837 F.3d 736 (7th Cir.) (explaining Rooker–Feldman doctrine)
- Dist. of Columbia Court of Appeals v. Feldman, 460 U.S. 462 (U.S.) (Rooker–Feldman foundational decision)
- Rooker v. Fid. Trust Co., 263 U.S. 413 (U.S.) (Rooker principle that only the Supreme Court may review state-court judgments)
- Bell v. City of Chicago, 835 F.3d 736 (7th Cir.) (argument waiver for issues not raised below)