Robertson v. United States, 3:17-cv-00321

Background

Plaintiff Luther Robertson, an Angola inmate proceeding pro se, sued under 42 U.S.C. § 1983 over a prison disciplinary hearing, seeking money and injunctive relief.
Alleged defects: false documents were placed in the disciplinary record, the hearing tape was turned off, and Robertson was prevented from calling witnesses.
Complaint named the United States but did not identify any individual person as a § 1983 defendant.
The Magistrate Judge reviewed the complaint under 28 U.S.C. §§ 1915(e) and 1915A for frivolousness and failure to state a claim.
The Magistrate concluded that issuance of a false disciplinary report, alleged procedural irregularities in investigation/hearing, or violations of prison rules do not, without more, establish a federal constitutional violation or a protected liberty interest invoking Wolff due process protections.
Recommendation: dismiss federal claims with prejudice as frivolous/for failure to state a claim and decline supplemental jurisdiction over any state-law claims.

Issues

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the complaint states a § 1983 claim where false reports and hearing irregularities are alleged	Robertson alleges false documents, tape turned off, and denial of witnesses violated his rights	No specific person was sued; mere procedural errors or false reports do not implicate constitutional rights absent a liberty interest or other consequence	Dismissed: § 1983 claim fails because no person named and allegations do not, by themselves, state a federal constitutional violation
Whether prison grievance/investigative failures create a due process right	Robertson seeks relief based on alleged inadequate investigation/handling of disciplinary matters	Prison grievance or investigative failings do not create a federally protected liberty interest	Dismissed: no due process right to favorable resolution or investigation of grievances
Whether alleged violations of prison rules alone give rise to constitutional claims	Robertson points to departures from prison policies during the disciplinary process	Violations of internal rules do not automatically equal constitutional violations	Dismissed: failure to follow prison rules does not state a constitutional claim
Whether alleged disciplinary process implicates Sandin/Wolff liberty interests	Robertson claims hearing defects deprived him of process	No allegation that punishment imposed an atypical and significant hardship or otherwise exceeded sentence	Dismissed: Sandin/Wolff due process protections not triggered; no protected liberty interest alleged

Key Cases Cited

Denton v. Hernandez, 504 U.S. 25 (1992) (standards for dismissing frivolous prisoner suits under § 1915)
Neitzke v. Williams, 490 U.S. 319 (1989) (dismissal standard for frivolous claims that lack arguable basis in law or fact)
Sandin v. Conner, 515 U.S. 472 (1995) (liberty interests for due process are limited to atypical and significant hardships)
Wolff v. McDonnell, 418 U.S. 539 (1974) (procedural due process protections in prison disciplinary proceedings when a protected liberty interest exists)
Wilkinson v. Austin, 545 U.S. 209 (2005) (clarifies atypical and significant hardship inquiry)
Geiger v. Jowers, 404 F.3d 371 (5th Cir. 2005) (no federal due process interest in having grievances resolved satisfactorily)
Grant v. Thomas, 37 F.3d 632 (5th Cir.) (issuance of false disciplinary reports alone does not state a due process violation)
Collins v. King, 743 F.2d 248 (5th Cir.) (same principle regarding false accusations and availability of state remedies)