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Woodson v. Gibbs

United States District Court, E.D. Pennsylvania

April 25, 2014

SEAN D. WOODSON, Plaintiff,
ERIC GIBBS, et al., Defendants.


CYNTHIA M. RUFE, District Judge.

Plaintiff Sean D. Woodson has filed a prisoner's civil rights complaint against several federal officials, alleging that they violated his constitutional rights by searching certain materials, which he characterizes as legal materials, stored in his cell, and not immediately returning those materials to him, and also challenging his conditions of confinement. Before the Court is Defendants' motion to dismiss Woodson's complaint for failure to state a claim. Woodson has not filed a response to the Motion. However, his Complaint does contain legal argument as to the viability of his claims, in addition to setting forth factual allegations.

I. Factual Allegations[1]

The events at issue occurred while Woodson was a pretrial detainee in federal custody, charged with being a felon in possession of a firearm. The Complaint alleges that on February 19, 2013, correctional officers entered Woodson's cell and removed him to a Special Housing Unit cell without his belongings. One officer then inventoried his property, which included six books, one of which was religious, and three feet of legal materials. From February 19, 2013, until March 22, 2013, Woodson repeatedly informed prison officials that he was representing himself in a pending criminal matter and needed access to his legal materials. The materials were not immediately returned.

On February 21, 2013, defendant Eric Gibbs informed Woodson that he was in the process of searching the materials from Woodson's cell. An unnamed prison official informed Woodson that defendants Eric Harris and Captain Nash were also searching his legal materials. On March 12, 2013, Woodson was told that employees of the United States Attorneys' Office were also searching and copying his legal materials. And on March 25, 2013, he was advised, through an affidavit of defendant William Jezior[2] that the Bureau of Alcohol, Tobacco, Firearms and Explosives had also participated in the search of Woodson's belongings. The Jezior affidavit stated that Woodson's properly marked outgoing legal mail had not and would not be opened during the search, and his properly marked incoming legal mail had not been opened and would not be opened outside of his presence, per the Bureau of Prison's policy. However, the affidavit stated that Woodson had improperly marked some general mail with a "legal mail" notation.

According to the Jezior affidavit, the search was initiated after the prison received a telephone call from Detective Muska of the State's Attorney's Office in Baltimore, Maryland, expressing suspicion that Woodson was forging court orders. Specifically, the Maryland officials suspected that Defendant had presented forged Orders of Expungement to various law enforcement agencies and the Baltimore County Court, in conjunction with a request to strike certain convictions from his record.

On March 6, 2013, Woodson's stand-by counsel, Peter Levin, Esq., wrote to advise him that defendants Jennifer Welsh and Marisa Davidson were alleging that Woodson was writing and selling documents to other prisoners, that he had a razor concealed in a court transcript, [3] that he was forging court documents with judges' signatures, and that he was paying a prisoner's wife to have her husband say a gun was his; the letter also advised Woodson that he was in the Special Housing Unit because their investigation of these issues was ongoing.

On March 22, 2013, Woodson was granted access to his legal materials. He found them to be in disarray and alleges that approximately 30 documents were missing. Woodson was permitted to take eight inches worth of legal materials back to his cell, and the remaining documents were stored elsewhere. Legal documents which appeared to be forgeries were not returned to Woodson, as they were considered contraband.

Defendant Jennifer Welsh later used documents found during this search to support her prosecution of Woodson on new criminal charges. On April 2, 2013, a grand jury returned a nine-count superseding indictment, five counts of which were obstruction of justice counts based on evidence of forged court documents and witness tampering found during the challenged search.[4] The District of Delaware denied Woodson's motion to suppress the evidence found during the prison cell search, finding that his legal materials had not been examined or copied during the search, and that the Fourth Amendment did not protect Woodson, as a pretrial detainee, against searches of his prison cell.[5]

Woodson now alleges that the search of his cell and seizure of his legal materials was unreasonable and unsupported by probable cause, in violation of his rights under the Fourth Amendment, because the cell search was initiated by a non-prison employee for reasons other than institutional security, [6] and written materials and contraband found during this search led to new criminal charges against him. He further alleges that the search violated his rights under the First and Sixth Amendments.[7] Finally, he alleges that the search led to his ongoing confinement in a windowless Special Housing Unit cell, which he asserts is a form of cruel and unusual punishment in violation of his rights under the Eighth Amendment.

II. Standard of Review

Pursuant to Federal Rule. of Civil Procedure 12(b)(6), dismissal of a complaint for failure to state a claim upon which relief can be granted is appropriate where a plaintiffs "plain statement" lacks enough substance to show that he is entitled to relief.[8] In determining whether a motion to dismiss should be granted, the court must consider only those facts alleged in the complaint, accepting the allegations as true and drawing all logical inferences in favor of the non-moving party.[9] Courts are not, however, bound to accept as true legal conclusions couched as factual allegations.[10] Something more than a mere possibility of a claim must be alleged; rather plaintiff must allege "enough facts to state a claim to relief that is plausible on its face."[11] The complaint must set forth "direct or inferential allegations respecting all the material elements necessary to sustain recovery under some viable legal theory."[12] The court has no duty to "conjure up unpleaded facts that might turn a frivolous... action into a substantial one."[13] Legal questions that depend upon a developed factual record are not properly the subject of a motion to dismiss.[14]

III. Discussion

A. Fourth Amendment ...

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