Steele v. Cicchi, No. 14-3127 (3d Cir. 2017)Annotate this Case
Pretrial detainee’s due process rights were not violated by placement in administrative segregation and restriction of phone privileges pending investigation of misconduct. While Steele was a pretrial detainee at New Jersey’s Middlesex County Adult Correction Center, officials received credible information that Steele was threatening other detainees in order to coerce them into using Speedy Bail Bond Service and was receiving compensation from Speedy. After interviewing Steele and advising him of the allegations, officials placed him in administrative segregation while they investigated. Steele’s telephone privileges were restricted to legal calls only. Steele filed suit under 42 U.S.C. 1983, claiming violations of his due process rights when the defendants transferred him to administrative segregation and restricted his phone privileges, interfering with his ability to find a co-signer for his own bail. The Third Circuit affirmed summary judgment for all defendants. Defendants’ limitation of Steele’s phone privileges did not “shock the conscience.” Steele has not met his heavy burden of showing that defendants exaggerated their response to the genuine security considerations that actuated his move. Steele’s transfer was for institutional security reasons rather than for discipline or punishment and he was accorded the required level of process.