Shinault v. Hawks, No. 13-35290 (9th Cir. 2015)
Annotate this CasePlaintiff, while incarcerated, received a $107,416.48 settlement from a medical liability claim against a drug manufacturer whose products caused him to develop diabetes. Counsel in the product liability suit deposited the settlement proceeds into plaintiff's inmate trust account. After the ODOC issued an order requiring plaintiff to pay $65,353.94 for the estimated cost of his incarceration and then subsequently froze and withdrew the funds at issue, plaintiff filed suit alleging various constitutional violations. The court concluded that plaintiff received insufficient due process as the result of Oregon's actions considering plaintiff's substantial interest, the risk of erroneous deprivation, and the ability to provide a hearing without compromising a significant government interest. Nor should providing a pre-deprivation hearing be administratively burdensome. However, the court affirmed the district court's grant of summary judgment to defendants considering no precedent established a state's obligation to provide a pre-deprivation hearing in these circumstances and thus, was not clearly established at the time of the conduct. Further, the court affirmed the district court's grant of summary judgment to defendants on plaintiff's Eighth Amendment claim where the withdrawal was a reimbursement rather than a punishment.
Court Description: Prisoner Civil Rights. The panel affirmed the district court’s summary judgment in an action brought by an Oregon state prisoner alleging that state officials violated his rights under the Fourteenth and Eighth Amendments when the Oregon Department of Corrections froze more than $60,000 in his inmate trust account to recover the cost of his incarceration. Plaintiff received a $107,416.48 settlement from a medical liability claim against a drug manufacturer whose products (prescribed while not in custody) caused him to develop diabetes. Addressing plaintiff’s procedural due process claim, the panel held that a state must provide a pre- deprivation hearing before freezing substantial inmate assets. The panel nevertheless affirmed the district court’s summary judgment in favor of defendants on the basis of qualified immunity because the constitutional obligation was not clearly established at the time of the conduct. Plaintiff also asserted that the freeze and withdrawal of his funds constituted deliberate indifference to his medical needs under the Eighth Amendment because he intended to use the funds to secure medical treatment following release from incarceration. Rejecting the Eighth Amendment claim, the panel held that prison officials did not deprive plaintiff of care during his period of incarceration and a state’s obligation SHINAULT V. HAWKS 3 to provide medical care does not extend to shielding assets in inmate accounts.
The court issued a subsequent related opinion or order on April 6, 2015.
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