Gregory D. Jones v. Jeffrey D. Spencer

25-1851Court of Appeals for the Seventh CircuitDec 4, 2025

Full text

United States Court of Appeals
For the Seventh Circuit
Chicago, Illinois 60604
Submitted December 3, 2025*
Decided December 4, 2025
Before
DAVID F. HAMILTON, Circuit Judge
CANDACE JACKSON-AKIWUMI, Circuit Judge
JOHN Z. LEE, Circuit Judge
No. 25-1851
GREGORY D. JONES,
Plaintiff-Appellant,
v.
JEFFREY D. SPENCER,
Defendant-Appellee.
Appeal from the United States District
Court for the Southern District of
Illinois.
No. 24-cv-01364-SMY
Staci M. Yandle,
Judge.
O R D E R
Gregory Jones, an Illinois prisoner, appeals the judgment dismissing his
complaint brought under 42 U.S.C. § 1983 challenging the constitutionality of a
disciplinary action taken against him. The district court dismissed the complaint for
* The appellee was not served with process and is not participating in this appeal. We have
agreed to decide the case without oral argument because the briefs and record adequately present the
facts and legal arguments, and oral argument would not significantly aid the court. FED . R. APP. P.
34(a)(2)(C).
NONPRECEDENTIAL DISPOSITION
To be cited only in accordance with F ED. R. APP . P. 32.1

-- 1 of 3 --

No. 25-1851 Page 2
failure to state a claim because Jones did not have a protected liberty interest implicated
by the discipline he received, an oral warning. We affirm.
We construe Jones’s pro se complaint liberally and assume the truth of his
allegations, as supplemented by the prison records he attached. See Otis v. Demarasse,
886 F.3d 639, 644 (7th Cir. 2018). In April 2023, Jones received a citation for violating a
rule that required prisoners to be ready each morning for inspection of their property
boxes. According to the disciplinary report, Jones broke the rule by sleeping through an
inspection. Two weeks later, the prison’s adjustment committee held a hearing on
Jones’s citation. The final summary report, signed by the committee’s chairperson,
Jeffrey Spencer, states that Jones attended the hearing, pleaded not guilty, requested no
witnesses, and ultimately admitted to the rule violation. Jones was punished with an
oral reprimand.
Jones later brought this § 1983 suit against Spencer for violating his rights under
the Due Process Clause of the Fourteenth Amendment in connection with the
disciplinary proceedings. Jones alleged that Spencer made false statements in the final
summary report, that no disciplinary hearing was held, that he had no opportunity to
call witnesses, and that he did not plead guilty.
The district judge screened Jones’s complaint under 28 U.S.C. § 1915A and
dismissed it because the oral warning did not implicate a liberty interest that triggered
the protections of the Due Process Clause. See Sandin v. Conner, 515 U.S. 472, 484 (1995).
The judge dismissed Jones’s remaining claims for failure to state a claim.
On appeal, Jones makes a narrow factual challenge, arguing that the district
court overlooked inconsistencies and falsifications in the final summary report. Jones
points to statements in the report, for instance, that he both pleaded not guilty and
made an admission of guilt. But these statements do not bear on this appeal. As the
court rightly concluded, Jones’s alleged punishment—an oral reprimand—is not an
“atypical and significant hardship … in relation to the ordinary incidents of prison life,”
Sandin, 515 U.S. at 484, and does not implicate any protected liberty interest, see Moore v.
Pemberton, 110 F.3d 22, 23 (7th Cir. 1997).
Jones also levels a charge of bias against the district judge, who, he says,
dismissed his case after he filed a complaint that accused her of misconduct. But
adverse rulings do not provide a valid basis to question a judge’s impartiality. Liteky v.

-- 2 of 3 --

No. 25-1851 Page 3
United States, 510 U.S. 540, 555 (1994). The district court’s decision was clearly correct,
beyond a reasonable debate.
AFFIRMED

-- 3 of 3 --

Continue your research in ChatGPT or Claude

Connect Omnilex to search the legal corpus from your AI assistant.