Spencer v. Haynes, No. 13-3460 (8th Cir. 2014)
Annotate this CaseWhile an inmate in Federal Correctional Institution - Forrest City, Spencer was assigned a cell for a medical assessment. Correctional Officer t Sheldon entered the cell to assist staff with checking Spencer's restraints. Spencer backed himself into a corner and was verbally abusive. Staff members told Spencer to sit on the bunk, but Spencer was uncooperative and aggressively resisted. While forcibly being placed on the bed, Spencer bit Sheldon's abdomen. Spencer was then placed in "four-point" restraints around 9:10 a.m. and was not removed from those restraints until 3:45 p.m. the following day. After a hearing, the Disciplinary Hearing Officer found that Spencer assaulted Sheldon and disciplined Spencer with losses of privileges. Spencer brought a petition for habeas corpus alleging a Fifth Amendment due process violation for being put in four-point restraints without being afforded a hearing. The district court dismissed without prejudice, finding that conditions-of-confinement claims cannot be raised in the context of habeas petitions. The Eighth Circuit remanded, stating that the court should liberally construe the pro se petition and decide the conditions-of-confinement claims under the principles of Bivens v. Six Unknown Named Agents.
Court Description: Prisoner case - Habeas. Circuit precedent precludes conditions-of-confinment claims using the vehicle of a habeas petition; however the district court should have liberally construed Spencer's pro se habeas petition and given him the option to pursue the claim under Bivens; remanded for further proceedings.
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