Taylor, Alan v. Dade Correctional Institution
1:25-cv-22884
| S.D. Fla. | Jun 29, 2025Background
- Plaintiff Alan Dwayne Taylor, a state prisoner, filed a pro se complaint under 42 U.S.C. § 1983 alleging that the Florida Department of Corrections (FDOC) classified him as guilty of a crime (aiding escape) for which charges were dropped in 2004.
- Taylor claims he was placed in confinement and later close management/solitary conditions between 2004–2005 based on those dismissed charges.
- He alleges this classification continues to affect him and violates his due process rights under the Fourteenth Amendment.
- Taylor seeks damages and asserts he could not file earlier due to being in a “psychotropic coma” from medication taken starting in 2004, which he stopped in March 2025.
- The court screened the complaint under 28 U.S.C. § 1915(e)(2)(B) since Taylor sought to proceed in forma pauperis.
- The court dismissed the complaint without prejudice for failure to state a claim and identified several deficiencies, allowing leave to amend.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Due Process: Atypical, significant hardship | Taylor suffered solitary confinement due to false escape classification | Not specified | Complaint lacks sufficient facts on hardship |
| Due Process: Procedural protections | Not specified | Not specified | No facts alleged about what process was provided |
| Personal involvement of named defendants | Continues to be classified by Dade CI officials | Not specified | No connection between named defendants & events |
| Statute of limitations | Filing tolled by psychotropic coma since 2004 | Not specified | No sufficient facts for equitable tolling shown |
Key Cases Cited
- Bell Atl. Corp. v. Twombly, 550 U.S. 544 (Pleading must provide more than labels and conclusions to state a claim.)
- Ashcroft v. Iqbal, 556 U.S. 662 (A complaint must state a plausible claim for relief to survive dismissal.)
- Sandin v. Conner, 515 U.S. 472 (Due process triggered only if prison conditions impose atypical and significant hardship.)
- Wallace v. Kato, 549 U.S. 384 (Statute of limitations for § 1983 claims is based on state’s personal injury limitations period.)
- Griffin v. City of Opa Locka, 261 F.3d 1295 (To state a § 1983 claim, deprivation must be by one acting under color of state law.)