Williams v. Director, Ohio Department of Rehabilitation and Corrections, 2:17-cv-01000

Plaintiff David A. Williams, a state prisoner proceeding pro se and in forma pauperis, sued Gary C. Mohr (Director, Ohio Dept. of Rehabilitation and Corrections) in his individual and official capacities seeking injunctive relief and damages for alleged wrongful conviction–related harms and conditions of confinement.
Williams alleges he was wrongfully convicted of crimes against a child, which exposed him to threats, assault, theft, slander/defamation, mental anguish, and discriminatory treatment (including over a haircut).
He claims harassment and safety risks from other inmates and staff, limitations and security risks in using the prison kiosk grievance system, and an inability to file grievances against Mohr directly.
Williams asserts he exhausted the grievance process to the best of his ability and faulted prison procedures and staff obstruction for any deficiencies.
The magistrate judge screened the complaint under 28 U.S.C. § 1915A and concluded the complaint lacks sufficient factual detail and fails to plead Mohr’s personal involvement; the recommendation is dismissal and denial of appointed counsel.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether complaint plausibly states Eighth Amendment/conditions claims against Mohr	Williams alleges threats, assaults, discrimination, and deprivation causing physical and mental harm tied to wrongful conviction and prison conditions	Mohr (via court) lacks alleged personal involvement; pleadings are conclusory and lack factual detail	Dismissed for failure to state a plausible claim; supervisory liability not shown
Whether prisoner may challenge lawfulness of conviction in §1983 action	Williams challenges wrongful conviction consequences and seeks relief for harms stemming from conviction	Court: challenge to conviction’s validity is the province of habeas corpus, not §1983	Such claims must be pursued via habeas; civil-rights action improper to the extent it attacks conviction
Whether failure-to-provide/defective grievance process gives rise to constitutional claim	Williams contends grievance kiosk limitations and staff obstruction prevented exhaustion and access to remedies	Court: there is no constitutional right to a grievance procedure or access to state-created grievance process	No constitutional claim based on grievance-process defects
Whether official-capacity money damages are barred by Eleventh Amendment	Williams seeks monetary relief from Mohr in official capacity	Eleventh Amendment bars suits for money against state officials in their official capacity	Official-capacity money claims are barred

Jourdan v. Jabe, 951 F.2d 108 (6th Cir. 1991) (pro se complaints are held to less stringent standards but still must state a cognizable claim)
Ashcroft v. Iqbal, 556 U.S. 662 (2009) (complaint must contain sufficient factual matter to state a plausible claim)
Bell Atl. Corp. v. Twombly, 550 U.S. 554 (2007) (plausibility standard for complaints)
Heck v. Humphrey, 512 U.S. 477 (1994) (habeas corpus is exclusive remedy for state prisoners challenging conviction or duration of confinement)
Combs v. Wilkinson, 315 F.3d 548 (6th Cir. 2003) (supervisory liability under §1983 requires personal involvement or encouragement of misconduct)
Thomas v. Arn, 474 U.S. 140 (1985) (failure to timely object to a magistrate judge’s report waives de novo review)
United States v. Walters, 638 F.2d 947 (6th Cir. 1981) (procedural waiver consequences for failure to object to magistrate recommendations)