Civil Rights-Prisoner

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7^th Circuit Court of Appeals

Case Name: Roy Sargeant v. Aracelie Barfield

Case No.: 21-2287

Officials: Hamilton, Scudder and Pryor, Circuit Judges.

Focus: Civil Rights-Prisoner

Federal inmate Sargeant lodged a grievance against prison official Cruze, citing her inappropriate comments about his sexual preferences and her refusal to provide him with ordered books. Upon reviewing the prison’s response with case manager Barfield, Sargeant noticed that Cruze had signed it, a violation of prison rules barring officials from viewing grievances filed against them. Sargeant brought this to Barfield’s attention, who subsequently disclosed the grievance to others. In response, Sargeant filed a separate grievance against Barfield. In retaliation, Barfield consistently placed Sargeant, a government-cooperating prisoner, in cells with known violent inmates, leading to altercations until Sargeant was eventually transferred to another facility.

Sargeant initiated a lawsuit seeking monetary damages, alleging that Barfield retaliated against him for filing grievances. However, he did not specify which constitutional rights Barfield had purportedly violated. During screening under 28 U.S.C. 1915A, the judge determined that Sargeant could proceed solely on a First Amendment retaliation claim, without addressing any potential Eighth Amendment claim. The Seventh Circuit upheld the dismissal of the complaint. According to the Bivens doctrine, a federal prisoner cannot recover damages for a violation of First Amendment rights. Acknowledging a failure-to-protect claim in this context would risk interfering with the federal prison system, posing separation-of-powers concerns and involving special factors not addressed by any Supreme Court Bivens precedents.

Decided 11/28/23

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