Hamner v. Burls, No. 18-2181 (8th Cir. 2019)Annotate this Case
Plaintiff filed suit under 42 U.S.C. 1983 against Arkansas prison officials, alleging deprivations of his constitutional rights while incarcerated. Plaintiff's claims stemmed from his almost seven month detention in administrative segregation.
The Eighth Circuit affirmed on the alternative ground that the complaint failed to adequately allege a violation of plaintiff's clearly established constitutional rights and therefore defendants were entitled to qualified immunity. The court explained that, although defendants did not raise qualified immunity in their motion to dismiss, the posture of the case has materially changed, and the court saw no bar to addressing qualified immunity. In regard to plaintiff's claim of deliberate indifference to his serious medical needs, the court held that defendants did not violate his clearly established rights. In this case, the nine occasions when plaintiff did not receive his daily treatment during his time in administrative segregation were insufficient to create an Eighth Amendment claim. In regard to plaintiff's claims related to his conditions of confinement, the court held that plaintiff failed to cite circuit precedent holding that an inadequate justification for administrative segregation or shortcomings in review of a prisoner's placement violates the Due Process Clause; defendants' conduct did not violate clearly established law; and it was not beyond debate that defendants curtailed plaintiff's liberty interest by segregating a prisoner with plaintiff's particular medical condition for 203 days under the conditions alleged.