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BROWN v. WINN REED (2021)

United States Court of Appeals, Ninth Circuit.2021-01-27No. No. 20-15376

Summary

Holding. The court affirmed the district court's dismissal because Brown failed to allege facts sufficient to state a plausible constitutional claim.

Eugene Carlton Brown, a California state prisoner, filed a civil rights suit under 42 U.S.C. § 1983 claiming that prison officials violated his First and Fourteenth Amendment rights by rejecting and disposing of his incoming mail. The district court dismissed the case, finding that Brown had not alleged sufficient factual details to support a legally viable claim. The appellate court reviewed the dismissal without deference to the lower court's reasoning and concluded that the district court properly applied the pleading standards.

Summary generated by law.co from the public-domain opinion. The opinion text itself is public domain.

Key issues

  • Whether prison mail restrictions violate First Amendment rights
  • Whether a prisoner stated a viable Fourteenth Amendment claim
  • Standards for evaluating pro se prisoner pleadings under Rule 1915A screening

Procedural posture

Brown appealed pro se from a district court dismissal of his § 1983 civil rights complaint challenging prison mail handling practices.

Authorities cited

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Opinion

MEMORANDUM **

California state prisoner Eugene Carlton Brown appeals pro se from the district courts judgment dismissing his 42 U.S.C. § 1983 action alleging First and Fourteenth Amendment violations in connection with the rejection and disposal of his incoming mail. We have jurisdiction under 28 U.S.C. § 1291. We review de novo a dismissal under 28 U.S.C. § 1915A. Wilhelm v. Rotman, 680 F.3d 1113, 1118 (9th Cir. 2012). We affirm.

The district court properly dismissed Browns action because Brown failed to allege facts sufficient to state a plausible claim. See Hebbe v. Pliler, 627 F.3d 338, 341-42 (9th Cir. 2010) (although pro se pleadings are liberally construed, a plaintiff must allege facts sufficient to state a plausible claim); see also Turner v. Safley, 482 U.S. 78, 89-91, 107 S.Ct. 2254, 96 L.Ed.2d 64 (1987) (infringement of a prisoners rights is permissible if carried out pursuant to a regulation that is reasonably related to a legitimate governmental interest); Hudson v. Palmer, 468 U.S. 517, 533, 104 S.Ct. 3194, 82 L.Ed.2d 393 (1984) (“[A]n unauthorized intentional deprivation of property by a state employee does not constitute a violation of the procedural requirements of the Due Process Clause of the Fourteenth Amendment if a meaningful post deprivation remedy for the loss is available.”); Ramirez v. Galaza, 334 F.3d 850, 860 (9th Cir. 2003) (“[I]nmates lack a separate constitutional entitlement to a specific prison grievance procedure[.]”).

AFFIRMED.