Reynolds v. Quiros, No. 19-2858 (2d Cir. 2021)
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Plaintiff, a prisoner serving a life sentence in Connecticut's Northern Correctional Institute, filed suit under 42 U.S.C. 1983, alleging that the conditions of his confinement violate his rights under Article I, Section 10 (the Bill of Attainder Clause) of the Constitution, as well as the Eighth and Fourteenth Amendments of the Constitution. On appeal, current and former Connecticut Department of Correction officials appeal the district court's judgment and permanent injunction principally granting plaintiff's motion for summary judgment and denying defendants' motion for summary judgment.
The Second Circuit held that the district court erred by deciding disputed issues of material fact in granting summary judgment in favor of plaintiff on his claims under the Eighth Amendment and the Due Process Clause of the Fourteenth Amendment; the district court correctly concluded that, with respect to plaintiff, Conn. Gen. Stat. 18-10b is an unconstitutional bill of attainder; and plaintiff's unreviewable classification score of Risk Level 5 violates his rights under the Equal Protection Clause of the Fourteenth Amendment because the difference in his treatment compared to that of other similarly-situated inmates lacks a rational basis. Accordingly, the court affirmed in part, vacated in part, and remanded.
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