Timothy N. Hatton v. Larry Storms

24-2131Court of Appeals for the Seventh CircuitDec 12, 2025

Full text

United States Court of Appeals
For the Seventh Circuit
Chicago, Illinois 60604
Submitted December 11, 2025*
Decided December 12, 2025
Before
FRANK H. EASTERBROOK, Circuit Judge
DIANE S. SYKES, Circuit Judge
MICHAEL Y. SCUDDER, Circuit Judge
No. 24-2131
TIMOTHY N. HATTON,
Plaintiff-Appellant,
v.
LARRY STORMS, et al.,
Defendants-Appellees.
Appeal from the United States District
Court for the Southern District of
Indiana, Indianapolis Division.
No. 1:22-cv-01417-MPB-MKK
Matthew P. Brookman,
Judge.
O R D E R
Timothy Hatton, an Indiana prisoner, appeals the summary judgment rejecting
his claims that prison employees wrongly interfered with his mail in violation of the
First Amendment and retaliated against him when he complained. See 42 U.S.C. § 1983.
We affirm.
* 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. F ED . R. A PP. P. 34(a)(2)(C).
NONPRECEDENTIAL DISPOSITION
To be cited only in accordance with FED. R. A PP. P. 32.1

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No. 24-2131 Page 2
Hatton filed his lawsuit in 2022, alleging, first, that prison employees at New
Castle Correctional Facility mishandled his mail (both incoming and outgoing) by
opening, destroying, delaying, and stealing it, and second, that they retaliated against
him for his complaints by placing him in segregation. He also alleged that the GEO
Group, Inc., the private company that contracted with the Indiana Department of
Correction to manage the prison, had mail-handling policies that authorize the
violations of the First Amendment. See Monell v. Dep’t of Soc. Servs., 436 U.S. 658 (1978).
Both Hatton and the defendants moved for summary judgment. The judge
summarily denied Hatton’s motion because Hatton failed to comply with Local Rule 56-
1 of the Southern District of Indiana. Hatton, the judge explained, did not file a
supporting brief or set forth a statement of undisputed material facts. And while Hatton
attached nearly 800 pages of documents to his motion, he did not cite page numbers or
specify which documents supported his arguments. The judge, however, granted the
defendants’ motion. According to the judge, Hatton offered insufficient evidence that
any opened mail was privileged, that any mail was missing, that any mail was delayed
for an impermissibly long time, that he was harmed as a result of any delay, that GEO
was the moving force behind any violation of the First Amendment, or that his
placement in disciplinary segregation was motivated by his engagement in protected
activity.
On appeal, Hatton challenges the district judge’s decision to enforce the local
rule and maintains that a more lenient approach to filing requirements should apply to
litigants like him who are proceeding pro se. But district judges have discretion to
enforce the local rules strictly, even against pro se litigants. See Robinson v. Waterman,
1 F.4th 480, 483 (7th Cir. 2021); Hinterberger v. City of Indianapolis, 966 F.3d 523, 528
(7th Cir. 2020). Regardless, Hatton’s summary judgment response did not question the
defendants’ version of the facts, so we see no abuse of discretion in the judge’s
application of the rule.
Hatton also generally contests the judge’s decision to grant the defendants’
motion for summary judgment. But he does not develop any challenge to disturb the
judge’s ruling. We have reviewed the record and affirm for substantially the same
reasons stated by the judge in his thorough opinion. See FED. R. A PP. P. 28(a)(8);
Anderson v. Hardman, 241 F.3d 544, 545–46 (7th Cir. 2001).
AFFIRMED

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