Toevs v. Reid, No. 10-1535 (10th Cir. 2011)
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Pro se Appellant Janos Toevs appealed the district court's grant of summary judgment to Defendants in his 42 U.S.C. 1983 civil-rights suit. Appellant's lawsuit pertained to the Colorado prison system's "Quality of Life Level Program" (QLLP). The QLLP program was described as a "stratified quality of life program based on increased levels of privileges for demonstrated appropriate offender behavior." Level 1 is the most restrictive, and each successive level offers an inmate more privileges. Appellant was placed in the QLLP in 2002 after attempting to escape. By September 2005, he had reached the least restrictive Level 6, but due to poor health was regressed back to Level 1. By 2009, Appellant had achieved Level 6 again and rejoined the general prison population. Appellant complained that during his placement in the QLLP from 2005 to 2009, his case managers' periodic reviews were "perfunctory, meaningless, and all said the same thing." He sued his case workers and the warden in their individual capacities. In affirming the district court's dismissal of Appellant's case, the Tenth Circuit found that the standards for meaningful periodic review for inmates in the QLLP were not previously clearly established in the Circuit. As such, the Court found that Defendants were entitled to qualified immunity from Appellant's suit.
The court issued a subsequent related opinion or order on April 2, 2012.
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