Sanders v. Page, No. 13-3237 (8th Cir. 2014)
Annotate this CaseSanders assisted another inmate by writing a letter to officials outside the Arkansas Department of Correction, asserting that Officer Page accepted a pair of ostrich-skin shoes made by the inmate. Sanders claimed that Page gave him favorable treatment to convince Sanders to dismiss the complaint. Sanders withdrew the complaint, but filed ADC grievances alleging Page improperly coerced him to withdraw his complaint and discussed with another inmate the "grave fabrication" that Sanders possessed a cell phone. Days later, officers, including Page, searched the barracks for contraband. They uncovered a cell phone in another inmate’s bunk. Sanders claimed that another officer warned Sanders that Page was going to file a disciplinary charge unless he withdrew his grievances. Days later, Page charged Sanders with use of a cell phone. A hearing officer found Sanders guilty. Sanders lost privileges and spent 30 days in isolation. The decision was upheld on ADC review. After a trial on his retaliatory-discipline claims (42 U.S.C. 1983), the jury awarded Sanders $1. The Eighth Circuit reversed and remanded with instructions to dismiss. Sanders received adequate notice, did not identify any witnesses or evidence he was not allowed to present, and received a copy of the decision.
Court Description: Prisoner case - Prisoner civil rights. In action alleging the defendant, a corrections officer, improperly filed a disciplinary charge against plaintiff in retaliation for plaintiff's actions in filing grievances against him, the officer was entitled to judgment as a matter of law as there was "some evidence" to support the discipline imposed against plaintiff and "some evidence" he committed the charged violation; reversed and remanded with directions to dismiss the complaint.
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