Proctor v. LeClaire, No. 11-3312 (2d Cir. 2013)
Annotate this CasePlaintiff, a New York State prisoner who had been administratively confined since 2003, appealed the district court's dismissal of his amended complaint. The complaint, brought pursuant to 42 U.S.C. 1983, alleged that plaintiff's due process rights have been violated because the decisions to continue his confinement in a Special Housing Unit (SHU) have been based on evidence that should have been expunged from his record, the periodic reviews have been perfunctory and meaningless, and the reasons given for his continued confinement have been false or misleading. Because plaintiff had previously lost a similar suit, the district court dismissed the complaint on the grounds that the present action was barred by principles of res judicata and collateral estoppel. The court concluded that the district court's applications of claim preclusion and issue preclusion, which the court reviewed de novo and in light of Computer Associates International, Inc. v. Altai, Inc., were in large part erroneous. Accordingly, the court vacated and remanded for further proceedings.
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