Tran v. Platt
2:11-cv-00152
S.D. Miss.Sep 18, 2013Background
- Tran, proceeding pro se, sues SMCI officials King, Platt, and Hartfield under 42 U.S.C. § 1983 for alleged due process violations at a disciplinary hearing.
- Plaintiff challenges a disciplinary RVR for contraband found in his cell and alleges errors in the RVR and hearing process.
- Defendants move for summary judgment on Eleventh Amendment immunity and qualified immunity; Plaintiff did not respond.
- Court finds Eleventh Amendment bars official-capacity monetary relief and Ex Parte Young does not bar retroactive relief; qualified immunity forecloses liability.
- Court grants summary judgment for Defendants on both official- and individual-capacity claims, concluding due process was not violated and immunity applies.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Eleventh Amendment bar on official-capacity claims | Tran seeks monetary relief and injunctive relief against King, Platt, Hartfield | Official-capacity claims are barred by Eleventh Amendment immunity | Official-capacity claims dismissed; Ex parte Young not applicable for retroactive relief |
| Qualified immunity in individual capacity | Due process was violated at the disciplinary hearing | Defendants acted reasonably; entitled to immunity | Qualified immunity applies; no personal liability for King, Platt, Hartfield |
| Due process at disciplinary hearing | denied viewing contraband; RVR contained errors | There was some evidence supporting the RVR; errors did not erase due process | No due process violation; some evidence supported the decision |
| Effect of ARP process on due process | ARP denial amounted to due process violation | ARP process provided adequate opportunity to be heard | No due process violation through ARP; hearing upholding found valid |
Key Cases Cited
- Hill v. Mass. Dept. of Corr., 472 U.S. 445 (1985) (some evidence standard applies to prison disciplinary decisions)
- Ex parte Young, 209 U.S. 123 (1908) (narrow exception to Eleventh Amendment for prospective injunctive relief)
- Mathews v. Eldridge, 424 U.S. 319 (1976) (two-step analysis for due process balancing)
- Zinermon v. Burch, 494 U.S. 113 (1990) (liberty/property interests and due process adequacy test)
- Pennhurst State Sch. & Hosp. v. Halderman, 465 U.S. 89 (1984) (sovereign immunity/waivers and limits of official-capacity suits)