Hatchett v. Warden
Filing
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MEMORANDUM OPINION. Signed by Chief Judge Deborah K. Chasanow on 9/16/2013. (c/m 9/16/2013 ns)(nss, Deputy Clerk)
IN THE UNITED STATES DISTRICT COURT
FOR THE DISTRICT OF MARYLAND
TIMOTHY HATCHETT
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Plaintiff
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v
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WARDEN
Defendant
Civil Action No. DKC-13-2645
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MEMORANDUM OPINION
The above-captioned case was filed on September 11, 2013. Plaintiff did not pay the
filing fee, nor did he file a Motion to Proceed in Forma Pauperis. Because the case must be
dismissed, he will not be required to correct the deficiency.
Plaintiff seeks an injunction against prison officials imposing lockdown conditions as to
him because the prison lockdown was not due to anything Plaintiff did personally. Rather,
Plaintiff asserts the lockdown was imposed after white officers allegedly armed a white inmate
with a kitchen knife, removed his restraints, and allowed him to stab a black inmate who
remained restrained during the attack. The inmates were members of rival gangs. Plaintiff
asserts that prison officials have created an atmosphere of racial tension within the prison that
has resulted in an increase in violence, placing him in fear of his safety and requiring him to live
under restrictive conditions while the prison remains on lockdown during an investigation into
the matter. ECF No. 1 at pp. 1 -3.
To state a civil rights claim, a prisoner must allege that he, himself, sustained a
deprivation of right, privilege, or immunity secured by Constitution or federal law. See Inmates
v. Owens, 561 F.2d 560, 563 (4th Cir. 1977). To demonstrate standing, a plaintiff must allege
personal injury fairly traceable to the defendant's allegedly unlawful conduct which is likely to
be redressed by the requested relief. See Allen v. Wright, 468 U.S. 737, 751 (1984). Petitioner
simply has no standing to assert the rights of another inmate who may have suffered harm as the
result of a constitutional violation. To the extent the Complaint seeks to redress the alleged
wrongs committed against other inmates, it fails to state a cognizable claim.
Conditions which "deprive inmates of the minimal civilized measure of life's necessities"
may amount to cruel and unusual punishment. Rhodes v. Chapman, 452 U. S. 337, 347 (1981).
However, conditions which are merely restrictive or even harsh, "are part of the penalty that
criminal offenders pay for their offenses against society." Id.
In order to establish the imposition of cruel and unusual
punishment, a prisoner must prove two elements - that 'the
deprivation of [a] basic human need was objectively sufficiently
serious,' and that 'subjectively the officials acted with a sufficiently
culpable state of mind.'
Shakka v. Smith, 71 F.3d 162, 166 (4th Cir. 1995) (emphasis in original; citation omitted).
“These requirements spring from the text of the amendment itself; absent intentionality, a
condition imposed on an inmate cannot properly be called “punishment,” and absent severity,
such punishment cannot be called “cruel and unusual.” Iko v. Shreve, 535 F.3d 225, 238 (4th Cir.
2008) citing Wilson v. Seiter, 501 U.S. 294, 298-300 (1991).
To establish a sufficiently culpable state of mind, there must be evidence that a known
excessive risk of harm to the inmate’s health or safety was disregarded. See Wilson, 501 U. S. at
298. In other words, “the test is whether the guards know the plaintiff inmate faces a serious
danger to his safety and they could avert the danger easily yet they fail to do so.” Brown v.
North Carolina Dept. of Corrections, 612 F.3d 720, 723 (4th Cir. 2010), quoting Case v. Ahitow,
301 F.3d 605, 607 (7th Cir. 2002). Conduct is not actionable under the Eighth Amendment
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unless it transgresses bright lines of clearly-established pre-existing law. See Maciariello v.
Sumner, 973 F. 2d 295, 298 (4th Cir. 1992).
The objective prong of a conditions claim requires proof of an injury. "[T]o withstand
summary judgment on an Eighth Amendment challenge to prison conditions a plaintiff must
produce evidence of a serious or significant physical or emotional injury resulting from the
challenged conditions." Strickler v. Waters, 989 F.2d 1375, 1381 (4th Cir. 1993). “Only
extreme deprivations are adequate to satisfy the objective component of an Eighth Amendment
claim regarding conditions of confinement.” De'Lonta v. Angelone, 330 F.3d 630, 634 (4th Cir.
2003). Demonstration of an extreme deprivation proscribed by the Eighth Amendment requires
proof of a serious or significant physical or emotional injury resulting from the challenged
conditions. See Odom v. South Carolina Dept. of Corrections, 349 F. 3d 765, 770 (4th Cir.
2003).
Imposition of lockdown conditions following violent attacks on prisoners and officers fall
within the ambit of restrictive conditions which are constitutionally permissible. Plaintiff’s
inability to participate in recreation or to take showers more than once every week, while harsh,
are not conditions that amount to cruel and unusual punishment, particularly where there is no
resultant injury alleged. Indeed, prison officials would be remiss in their responsibilities to
investigate and address the incidents as described by Plaintiff if lockdown conditions were not
put into place in their wake. A separate Order dismissing the Complaint follows.
September 16, 2013
Date
___________/s/____________________
DEBORAH K. CHASANOW
United States District Judge
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