Williams v. Utah Department of Corrections

Believing that Utah state law required the Utah Department of Corrections ("UDOC") to pay interest on prison accounts, plaintiff-appellant Reginald Williams investigated the relationship between UDOC and Zions First National Bank (Zions Bank). Based on his investigation, he concluded that Zions Bank had a contract with UDOC to hold prisoner funds in an account administered by UDOC, and that the interest earned on the funds was illegally retained by the bank, when it should have been paid to the prisoners who owned the funds. Williams believed that, in response to this investigation, UDOC retaliated against him by, among other things, seizing his legal papers and giving him a negative parole report, which resulted in the denial of parole. He claimed that he was a model prisoner who was similarly situated to other prisoners who had been granted parole. Proceeding pro se, Williams filed suit pursuant to 42 U.S.C. 1983 against UDOC, numerous prison officials, Zions Bank, and several Zions Bank employees, alleging takings and due-process constitutional violations for withholding interest on inmate funds, and retaliation in violation of the First Amendment for raising these issues. After the district court appointed counsel for Williams, all defendants moved to dismiss. The district court dismissed all claims except the retaliation claim, and dismissed all defendants except five prison officials. The remaining defendants then filed a motion for summary judgment on the retaliation claim, which the district court granted. In their motion to dismiss, UDOC and the prison-official defendants asserted Eleventh Amendment immunity, claiming that as an arm of the State of Utah, UDOC was immune from suit, and that the prison personnel were similarly immune from suit for claims against them in their official capacities. Williams presented no argument regarding the Eleventh Amendment, and the district court did not address Eleventh Amendment immunity in any of its rulings. On appeal, the UDOC Defendants renewed their argument that they were immune from suit under the Eleventh Amendment. Finding that the Supreme Court’s recent holding in Knick v. Twp. of Scott, No. 17-647, 2019 WL 2552486 (U.S. June 21, 2019) that a property owner could bring a federal suit claiming a Fifth Amendment taking without first bringing suit in state court, the Tenth Circuit concluded Knick did not involve Eleventh Amendment immunity, which was the basis of its holding in this case. Therefore, the Court held the takings claim against the UDOC Defendants had to be dismissed based on Eleventh Amendment immunity; the matter was remanded to the district court with instructions to dismiss it without prejudice. View "Williams v. Utah Department of Corrections" on Justia Law