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Carlton Wayne Mitchell v. Jack Kirk Jerome Weiler Vivian Watts Dick Moore George Lombardi Bill Armontrout William L. Rutledge Larry Henson Robert Acree Tom Davis, Captain Burris, Captain Holtmeyer, Lt. Vance, Lt. Richard Childs Roy Heyer, Lt. Michael Co I Dixon Walter Richter, Sgt. Cavanaugh, Sgt. Jack Dreyer, Sgt. C. Davis, Sgt. Co I Rex John Doe, Co I Co I Finley Seabrooks, Co I Medlock, Co I Randy Ray, Co I Floyd George Gerald Bommell Mark Schreiber Oscar Dunbar Daniel Kempker David Webster Randall Mobley Clifton S. Bowen G. Jobe M.A. Counterman David Kormann Gail Hughes Donald Gerling Leible Exchange National Bank the Central Trust Bank Don Perdue Don Campbell Charles Dudenhoeffer, Jr. Joseph Driskill
Citations: 20 F.3d 936; 1994 U.S. App. LEXIS 6519Docket: 92-2202
Court: Court of Appeals for the Eighth Circuit; April 7, 1994; Federal Appellate Court
Carlton Wayne Mitchell, a Missouri inmate, filed a 42 U.S.C. § 1983 action against several prison officials, guards, two banks, and a state legislator, alleging excessive force by prison guards. The district court allowed this claim to proceed to trial but dismissed other claims. After a jury found in favor of the prison guards, Mitchell appealed, claiming judicial bias due to the district judge's conduct and remarks during the trial. The appellate court reviewed the claim for plain error since Mitchell did not object during the trial. It concluded that the judge's comments were appropriate for maintaining courtroom decorum and did not exhibit bias or partiality. The court noted that even heated exchanges between the judge and Mitchell were aimed at managing the trial rather than influencing its outcome. Furthermore, the judge's refusal to recuse himself was upheld, as his remarks did not demonstrate the deep-seated antagonism required for disqualification. Thus, the appellate court affirmed the lower court's decision. Mitchell's claims against prison officials, banks, and bank employees for violating his right to earn interest on his prison bank account were dismissed correctly. Even if a constitutional right to earn interest existed, Missouri prison regulations that prohibit individual interest-bearing accounts serve valid penological purposes and do not constitute a violation. The dismissal of claims against banks and their employees was also appropriate because they did not act under color of state law, as merely opening a noninterest-bearing account does not satisfy the requirements for liability under Section 1983. Additionally, Mitchell's claim against a state legislator, which stemmed from a letter questioning another prisoner's privileges that allegedly caused him to lose his prison job, was dismissed because he has no constitutional right to a specific job in prison. The legislator is protected by absolute immunity as writing such a letter is part of legitimate legislative activity. Consequently, the district court's dismissals of all claims were affirmed.