Smith v. McKinney, No. 18-3613 (8th Cir. 2020)
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The Eighth Circuit affirmed the district court's grant of summary judgment in favor of prison officials in a 42 U.S.C. 1983 action brought by plaintiff, alleging violation of his due process rights in connection with discipline imposed on him. The court held that the conditions of confinement that plaintiff faced during administrative segregation and upon his transfer to the Iowa State Penitentiary did not amount to an atypical and significant deprivation when compared to the ordinary incidents of prison life.
The court held that the transfer to a higher security facility alone is insufficient to establish an atypical and significant hardship, and thus the court must examine the conditions of confinement. In this case, plaintiff failed to set forth facts describing his conditions of confinement while in administrative segregation and disciplinary detention. Furthermore, plaintiff's reference to his loss of employment, wages, security classification, security points, and inmate tier status upon his transfer did not amount to atypical and significant hardship under precedent.
Court Description: [Smith, Author, with Loken and Grasz, Circuit Judges] Prisoner case - Prisoner civil rights. The conditions of confinement plaintiff endured in segregation and upon his transfer to the Iowa State Penitentiary did not impose on him an atypical and significant hardship in relation to the ordinary incidents of prison life; transfer to a higher security facility alone is insufficient to establish an atypical or significant hardship and demotion to segregation, without a detailed description of the conditions of confinement, is not itself an atypical and significant hardship; loss of privileges, such as employment and wages, does not amount to an atypical or significant hardship.
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