Williamson v. Stirling, No. 17-6922 (4th Cir. 2018)Annotate this Case
Plaintiff appealed the district court's grant of summary judgment in favor of DOC officials in an 42 U.S.C. 1983 action alleging due process violations. Plaintiff claimed that, as a result of actions of defendants, he suffered in solitary confinement for three-and-a-half years while in pretrial detention, in violation of his Fourteenth Amendment rights.
Determining that it had appellate jurisdiction and the due process claims were not moot, the Fourth Circuit held that Defendants Charlton and Miller were entitled to summary judgment on each of the due process claims because they lacked sufficient personal involvement in the alleged constitutional deprivations. The court held, however, that Director Stirling and Sheriff Carroll were not entitled to qualified immunity on plaintiff's substantive and procedural due process claims arising from plaintiff's solitary confinement as a safekeeper. Because neither the report or the summary judgment properly applied the legal principles that control substantive and procedural due process claims being pursued by a pretrial detainee, the court held that the district court erred in awarding summary judgment to Director Stirling and Sheriff Carroll on these claims.