Daniels v. Murphy
A court can deny an inmate's request to amend his complaint, to allege he is unable to earn good time credit, because he has been designated as a security risk group safety threat, when discovery deadlines have passed, and the addition of new claims will prejudice the defendants. In 2010, the plaintiff allegedly was designated as a security risk group safety threat and confined to his prison cell at Northern Correctional Institution 23 hours per day. The plaintiff, who had a musculoskeletal injury, allegedly was not permitted to wear his brace. He was handcuffed with hands behind his back during recreation periods. The plaintiff sued and alleged it was dangerous for him to be handcuffed with hands behind his back, because he was disabled, and that he experienced back pain and was unable to exercise. The plaintiff alleged that the defendants were deliberately indifferent to a serious medical need, which required that he use a cane and be assigned a bottom bunk. The plaintiff requested injunctive relief and monetary damages. The court denied the plaintiff's request to amend, to add information about constitutional amendments that the defendants allegedly violated. The court also denied the plaintiff's request to amend, to add the allegations that he is unable to earn good time credit, because of his designation as a security risk group safety threat, and that he has been denied access to a law library. The plaintiff may amend his complaint once as of right, and he has already amended his complaint more than once. Discovery deadlines have passed. The addition of new claims will prejudice the defendants. The plaintiff also requested an injunction, because prison officials transferred the plaintiff to Osborn Correctional Institution, and he allegedly did not receive adequate back, leg, knee, hip and foot treatment in October 2012. A doctor allegedly ordered medical treatment in November, and the court found that the plaintiff's request for injunctive relief was moot. The plaintiff requested a copy of the defendants' security risk group documents. The defendants allegedly redacted names and other information. The court denied the plaintiff's motion to compel as moot.