Smith v. Alaska, Department of CorrectionsAnnotate this Case
Two prisoners in Alaska Department of Corrections’ (DOC) custody were placed in administrative segregation pending an investigation and disciplinary proceedings related to an alleged escape attempt. The disciplinary decisions were later overturned on appeal to the superior court based on procedural defects. However, the prisoners had lost their Prison Industries jobs because of the administrative segregation placements. They filed a civil suit against two DOC officers in superior court, alleging due process violations and seeking damages for lost wages and property. The case was removed to federal court; the federal judge ruled that the inmates lacked a constitutionally protected interest in their jobs and that the DOC officers were entitled to qualified immunity. Meanwhile, the prisoners filed another complaint in the superior court, this time naming the officers in both their official and individual capacities and raising due process claims under both the United States and Alaska Constitutions. After both parties cross-moved for summary judgment, the superior court granted summary judgment for the DOC officers, finding that although the federal judgment did not bar the prisoners’ complaint under the doctrine of res judicata, their constitutional claims lacked merit and the DOC officers were entitled to qualified immunity. The prisoners appealed to the Alaska Supreme Court, arguing they had a constitutionally protected interest in their jobs; that this interest was clearly established and therefore precludes a qualified immunity defense; that the superior court made various procedural errors; and that it did not adequately instruct the unrepresented prisoners on how to pursue their claims. Because the Supreme Court found the administrative segregation hearings conducted by DOC satisfied any due process requirements to which the prisoners may have been entitled, and because the superior court did not abuse its discretion in any of its procedural rulings, it affirmed the superior court’s grant of summary judgment.