Ford v. Bender, No. 12-1622 (1st Cir. 2014)Annotate this Case
While Plaintiff was imprisoned in the Massachusetts Department of Correction (DOC) he committed misconduct that resulted in an administrative sanction of a ten-year term in the Department Disciplinary Unit (DDU), a segregated maximum security housing unit, as well as a state law criminal charge for armed assault with intent to murder. After Plaintiff completed his original criminal sentence he remained in the custody of the DOC as a pretrial detainee for the new criminal assault with intent to murder charge. After Plaintiff was sentenced on the criminal charge, he continued to serve out the balance of the ten-year administrative sanction in the DDU. The district court ruled that two high-ranking prison officials had violated Plaintiff’s due process rights by continuing to confine Plaintiff in the DDU, both as a pretrial detainee and as a sentenced inmate. In connection with these rulings, the court denied the defendants’ claims of qualified immunity and awarded Plaintiff partial money damages and equitable relief as well as attorneys’ fees and costs. The First Circuit reversed the denial of qualified immunity, reversed the award of money damages against the officials in their individual capacities and vacated all equitable relief, holding that the prison officials did not violate Plaintiff’s clearly established rights. Remanded.