Williams v. Harmon, et al., No. 10-2465 (8th Cir. 2011)
Annotate this CasePlaintiff filed suit pursuant to 42 U.S.C. 1983, alleging, inter alia, that his approximately 14-year detention in administrative segregation (Ad. Seg.) violated his procedural due-process rights under the Fourteenth Amendment because the periodic reviews of his detention were not meaningful. The district court subsequently found that four of the five defendants had in fact denied plaintiff due process by conducting meaningless Ad. Seg. review hearings and consequently, awarded him $4,846 in nominal damages - $1 for every day that plaintiff lived in Ag. Seg. - but denied plaintiff prayer for punitive damages. Both parties appealed. The court held that the district court did not clearly err in its factual findings as to the meaningfulness of plaintiff's Ad. Seg. reviews and affirmed that portion of the district court's decision. The court also held that plaintiff was entitled to no more than $1 for each procedurally defective Classification Committee hearing. Thus, based on this "per-constitutional-violation" analysis, the court reversed the district court's nominal damages award and remanded for recalculation. The court further held that it could not conclude that the district court abused its discretion on the record and affirmed the district court's denial of compensatory damages. The court finally held that the district court did not err in refusing to award plaintiff punitive damages.
Court Description: Prisoner case - prisoner civil rights. For the court's prior opinion in this action alleging plaintiff's 14-year detention in administrative segregation violated his procedural due process rights because the periodic reviews of his continued detention were not meaningful, see Williams v. Norris, 277 F. App'x 647 (8th Cir. 2008). District court did not clearly err in finding that defendants' administration of the review process was not meaningful for purposes of the due process clause as the record showed the defendants gave undue weight to past facts and failed to provide Williams, with any reasonable specificity, reasons for their belief that he constituted a continued threat to security and order in the institution; district court erred in calculating the measure of Williams's nominal damages as each day spent in administrative segregation did not constitute a separate constitutional violation; instead the faulty 60-day classification reviews were the pertinent deprivation and Williams is entitled to $1 for each procedurally defective review hearing; case remanded for recalculation of damages; district court did not abuse its discretion by denying Williams's request for compensatory or punitive damages. Judge Loken, dissenting.
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