O'BRYANT v. Finch
2011 U.S. App. LEXIS 6877
| 11th Cir. | 2011Background
- O'Bryant, a Florida prisoner serving two life terms, was housed at Holmes Correctional Institution during the relevant events.
- HCI staff Defendants Herring and Baines issued disciplinary reports against O'Bryant for alleged disrespect, following disputes on December 14 and 17, 2004.
- A December 13, 2004 cell search by Defendant Finch found contraband but was not charged; O'Bryant alleged it was done in retaliation for his grievances.
- Disciplinary hearings were conducted under Wolff and Hill requirements; O'Bryant received notice, opportunity to present evidence, and written decisions after hearings where he contested the charges.
- O'Bryant was found guilty on both Herring and Baines disciplinary reports and sentenced to 30 days' disciplinary confinement on each count; he appealed without success.
- The district court granted summary judgment to Herring, Baines, Peters, Pittman, Taylor, and Rhynes, and a bench trial favored Finch; on appeal, the Eleventh Circuit affirmed, addressing retaliation claims and due process.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether Herring and Baines violated the First Amendment by retaliating for grievances | O'Bryant contends false DRs were issued to punish grievances. | Defendants assert due process supported convictions; retaliation claim premised on false reports fails if actual discipline followed. | Retaliation claim fails; convictions for actual misconduct bar retaliation claim and no causal link shown. |
| Whether the disciplinary proceedings satisfied due process under Wolff and Hill | O'Bryant asserts inadequate process in investigations/hearings. | Defendants argue process complied with Wolff/Hill and protections beyond them. | O'Bryant received due process; procedures satisfied Wolff and Hill standards. |
| Whether there is a causal connection between grievances and discipline | Grievances motivated the DRs against O'Bryant. | Discipline would have occurred regardless of grievances; actions based on actual rule violations. | No causal connection; even assuming some motive, same discipline would have occurred absent grievances. |
Key Cases Cited
- Wolff v. McDonnell, 418 U.S. 539 (U.S. (1974)) (due process in prison disciplinary proceedings and required notice, evidence, and written decision)
- Hill v. Hill, 472 U.S. 445 (U.S. (1985)) (some evidence standard for disciplinary sanctions; due process not as in criminal trials)
- Smith v. Mosley, 532 F.3d 1270 (11th Cir. 2008) (protected speech and retaliation framework; Mt. Healthy burden-shifting approach)
- Moton v. Cowart, 631 F.3d 1337 (11th Cir. 2011) (causation in retaliation claims; not all grievances lead to disciplinary action)
- Hartsfield v. Nichols, 511 F.3d 826 (8th Cir. 2008) (retaliation defenses when actual discipline follows; some evidence could support findings)