Halcomb v. Ravenell, No. 19-6843 (4th Cir. 2021)
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The Fourth Circuit reversed the district court's denial of defendant's motion for summary judgment based on qualified immunity in a 42 U.S.C. 1983 action brought by plaintiff, who is serving a life sentence. Plaintiff filed suit alleging that defendant violated his right to due process by failing to provide advance notice of a security detention hearing that led to more restrictive confinement.
The court assumed without deciding that a due process violation occurred and conclude that, even so, the right to fair notice of a security detention hearing was not clearly established at the time such that a reasonable official would have known that plaintiff had the right to be notified prior to his security detention hearing. Accordingly, the court remanded with instructions to enter an order granting the motion.
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