James Spann v. George Lombardi, No. 21-3455 (8th Cir. 2023)
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Plaintiff sued Missouri prison officials under 42 U.S.C. Section 1983, alleging deprivations of his constitutional rights while incarcerated. The officials moved for summary judgment based on qualified immunity, and the district court denied the motion on two sets of claims. The officials appealed a portion of the order.
The Eighth Circuit reversed. The court explained that even assuming for the sake of analysis that Plaintiff enjoyed a clearly established liberty interest in avoiding assignment to administrative segregation, it was not clearly established that he was entitled to the procedures set forth in Wolff v. McDonnell, 418 U.S. 539. Further, the court explained that a reasonable official could have believed that the procedures applied in Plaintiff’s case were constitutionally sufficient. Informal due process requires only “some notice of the reasons for the inmate’s placement . . . and enough time to prepare adequately for the administrative review.” The procedures applied here meet the informal due process standard. The officials gave Plaintiff adequate notice of the reasons for his placement. The notice informed Plaintiff of his rights and identified the alleged victim, the date of the sexual assault, and the prison rule that he allegedly violated.
Court Description: [Colloton, Author, with Shepherd and Grasz, Circuit Judges] Prisoner case - Prisoner civil rights. For the Court's prior opinion in the matter, see Spann v. Lombardi, 960 F.3d 1085 (8th Cir. 2020). Even assuming for the sake of analysis that plaintiff enjoyed a clearly established liberty interest in avoiding assignment to Administrative Segregation, it was not clearly established that he was entitled to the procedures set forth in Wolff v. McDonnell, 418 U.S. 539 (1974) as the Wolff procedures do not apply when an inmate is transferred to Administrative Segregation; instead, a transfer to Administrative Segregation requires only informal, non-adversary due process procedures like those set out in Hewitt v. Helms, 459 U.S. 460 (1983) and Greenholtz v. Inmates of Nebraska Penal Complex, 442 U.S. 1 (1979); in light of this, a reasonable prison official could have believed that the procedures applied in plaintiff's case were constitutionally sufficient, and the prison officials were entitled to qualified immunity on plaintiff's due process claim; with respect to plaintiff's allegations of retaliatory discipline, the violation reports regarding plaintiff's alleged misconduct meet the "some evidence" standard established in Hartsfield v. Nichols, 511 F.3d 826 (8th Cir. 2008), and the jail officials were entitled to qualified immunity on plaintiff's claims alleging retaliatory discipline.
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