Thomas 254903 v. Piggett
1:25-cv-00020
W.D. Mich.Apr 14, 2025Background
- Plaintiff, Ronnie Dante Thomas, is an inmate at Bellamy Creek Correctional Facility (IBC) who brought a pro se civil rights action under 42 U.S.C. § 1983 against several IBC officers.
- Thomas alleged that, following a medical order for two pillows due to thyroid nodules, IBC officers repeatedly refused to provide the accommodation while he was in protective custody.
- Thomas claimed these actions violated his rights under the First, Eighth, and Ninth Amendments, constituted ADA violations, RICO violations, and tortious interference with business relationships.
- The court screened the complaint under the PLRA, which requires dismissal if claims are frivolous, fail to state a claim, or seek monetary relief from immune defendants.
- Motions for a preliminary injunction and to exclude claims from PLRA screening were also filed by Thomas.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| 1st Amendment Retaliation | Verbal complaints about pillow denial led to continued denial | Conduct not motivated by protected activity | Thomas failed to plausibly allege retaliation; claim dismissed |
| 1st Amendment Access to Courts | Pillow denial hindered court access, incl. business interests | No actual injury to court access | No actual injury, non-cognizable claim; claim dismissed |
| 8th Amendment Deliberate Indifference | Denial of pillows violated medical needs | No deliberate indifference, no harm shown | No showing of deliberate indifference; claim dismissed |
| ADA & RICO Violations | Denial violates ADA, RICO due to alleged disability/business harm | No plausible facts or predicate acts | No sufficient allegation for ADA/RICO; claims dismissed |
| State Law Tortious Interference | Actions harmed business interests (Trust and LLC) | No facts showing interference or damages | No valid claim or standing pro se for entities; claim dismissed |
Key Cases Cited
- Haines v. Kerner, 404 U.S. 519 (1972) (pro se complaints must be construed liberally)
- Denton v. Hernandez, 504 U.S. 25 (1992) (courts accept as true all but the wholly incredible allegations)
- Bell Atl. Corp. v. Twombly, 550 U.S. 544 (2007) (claims require plausible factual basis)
- Ashcroft v. Iqbal, 556 U.S. 662 (2009) (conclusory allegations are insufficient)
- West v. Atkins, 487 U.S. 42 (1988) (section 1983 requires violation of federal right by state actor)
- Estelle v. Gamble, 429 U.S. 97 (1976) (deliberate indifference standard for inmate medical claims)
- Farmer v. Brennan, 511 U.S. 825 (1994) (requires subjective knowledge of substantial risk)
- Lewis v. Casey, 518 U.S. 343 (1996) (actual injury required for access-to-courts claim)
- Bounds v. Smith, 430 U.S. 817 (1977) (prisoners have right of access to courts)
- Christopher v. Harbury, 536 U.S. 403 (2002) (access-to-courts claim must specify underlying action)
- Thaddeus-X v. Blatter, 175 F.3d 378 (6th Cir. 1999) (elements of prison retaliation claim)