Proctor v. LeClaire, No. 15-3673 (2d Cir. 2017)Annotate this Case
Plaintiff, an inmate confined in solitary confinement for the last twenty-two years, filed suit under 42 U.S.C. 1983 against current and former prison officials, alleging that his solitary confinement under Administrative Segregation violates his Fourteenth Amendment rights to procedural and substantive due process of law. The district court granted defendants' motion for summary judgment on plaintiff's procedural due process claim, and sua sponte awarded summary judgment on the substantive due process claim. The court concluded that the record presents triable issues of fact regarding plaintiff's procedural due process claim. In this case, although there exists on the record a substantial amount of evidence for a jury to conclude that officials where methodical in their approach to conducting periodic Administrative Segregation reviews, the court concluded that plaintiff has nonetheless produced evidence to raise a fair question about the meaningfulness, and thus procedural sufficiency, of his reviews. The court also concluded that the district court violated Federal Rule of Civil Procedure 56(f) in awarding summary judgment sua sponte on plaintiff's substantive due process claim. Accordingly, the court vacated and remanded for further proceedings.