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Slip Opinion
N.D.N.Y.
2022
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Background

  • Pro se plaintiff Charles J. Smith, an inmate at Cayuga Correctional Facility, sued Corrections Officer Jaynes under 42 U.S.C. § 1983 alleging First Amendment retaliation arising from a July 19, 2018 incident.
  • Smith worked in the mess hall and requested to go to the law library; Jaynes says Smith refused a direct order and issued a misbehavior report.
  • After the report, Smith was placed in the Special Housing Unit and, following a hearing, was found guilty; that determination was affirmed on administrative appeal.
  • Smith filed at least one grievance the same day (logged as CAY-18375-18 and categorized as an inmate property grievance); the court previously held that grievance did not exhaust his retaliation claim.
  • Cross-motions for summary judgment were filed: Smith sought judgment on his claim; Jaynes moved for judgment on exhaustion and merits. The magistrate judge recommends granting Jaynes’ motion and denying Smith’s motions.

Issues

Issue Plaintiff's Argument Defendant's Argument Held
Whether Smith exhausted administrative remedies under the PLRA Smith contends grievances were unavailable or lost and that he filed multiple grievances (including an unprocessed retaliation grievance) Jaynes shows Smith successfully used the grievance system on other occasions and the only recorded grievance was categorized as a property grievance; no proof the alleged retaliation grievance was ever filed/processed Court: Smith failed to properly exhaust; Ross exceptions inapplicable; defendant entitled to summary judgment on exhaustion grounds
Whether Smith engaged in protected conduct / suffered adverse action Smith asserts he asked to go to the law library and to speak to a supervisor and that being forced to clean and receiving a misbehavior report were retaliatory Jaynes argues the request to speak to a supervisor is not protected, directing mess-hall work was not adverse, and the misbehavior report was justified by Smith’s conduct Court: Court assumed library request and report satisfy protection/adversity for argument’s sake but found other elements lacking
Causation / retaliatory motive (link between protected activity and misbehavior report) Smith alleges Jaynes retaliated (refers generally to earlier incidents and “winds of retaliation”) Jaynes points to the guilty finding at the disciplinary hearing and absence of any statements showing retaliatory motive Held: No triable issue of retaliatory motive or causation; guilty finding supports that the report would have been issued regardless of alleged animus
Qualified immunity for Jaynes N/A (Smith argues constitutional violation) Jaynes asserts qualified immunity because reasonable officers could disagree about issuing discipline and record supports nonretaliatory basis Held: Jaynes entitled to qualified immunity; the unlawfulness was not clearly established given the valid disciplinary outcome

Key Cases Cited

  • Porter v. Nussle, 534 U.S. 516 (2002) (PLRA exhaustion requirement applies to all inmate suits)
  • Ross v. Blake, 578 U.S. 632 (2016) (exceptions when grievance remedies are effectively unavailable)
  • Woodford v. Ngo, 548 U.S. 81 (2006) (requires "proper" exhaustion following procedural rules)
  • Celotex Corp. v. Catrett, 477 U.S. 317 (1986) (summary judgment burden rules)
  • Matsushita Elec. Indus. Co. v. Zenith Radio Corp., 475 U.S. 574 (1986) (summary judgment and inferences)
  • Holland v. Goord, 758 F.3d 215 (2d Cir. 2014) (elements of a prisoner First Amendment retaliation claim)
  • Espinal v. Goord, 558 F.3d 119 (2d Cir. 2009) (retaliation claim framework)
  • Graham v. Henderson, 89 F.3d 75 (2d Cir. 1996) (protected conduct must be a substantial or motivating factor)
  • Dawes v. Walker, 239 F.3d 489 (2d Cir. 2001) (courts should view prisoner retaliation claims with skepticism)
  • Reichle v. Howards, 566 U.S. 658 (2012) (qualified immunity standard)
  • Malley v. Briggs, 475 U.S. 335 (1986) (qualified immunity protects all but plainly incompetent officials)
  • Anderson v. Creighton, 483 U.S. 635 (1987) (unlawfulness must be apparent under pre-existing law)
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Case Details

Case Name: Smith v. Jaynes
Court Name: District Court, N.D. New York
Date Published: Feb 18, 2022
Citations: 2022 WL 686627; 9:18-cv-01107
Docket Number: 9:18-cv-01107
Court Abbreviation: N.D.N.Y.
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