Chappell v. Mandeville, et al, No. 09-16251 (9th Cir. 2013)
Annotate this CasePlaintiff brought a 42 U.S.C. 1983 suit against officials from the California State Prison, alleging constitutional violations relating to his six-day placement on contraband watch. Plaintiff was placed on contraband watch after three unlabeled bottles found in his prison cell tested positive for methamphetamine. The district court granted defendants' motion for summary judgment in part but denied summary judgment with respect to plaintiff's Eighth Amendment and due process claims against Defendant Mandeville and Rosario. The court held that both Defendant Mandeville and Rosario were entitled to qualified immunity because the law at the time plaintiff was on contraband watch did not clearly establish that their actions were unconstitutional.
Court Description: Prisoner Civil Rights. The panel reversed the district court’s denial of a motion for summary judgment brought by two California state prison officials in this 42 U.S.C. § 1983 action in which plaintiff alleged Eighth Amendment and due process violations in connection with his six-day placement on contraband watch. The panel concluded that, as of April-May 2002, the law was not clearly established as to whether the conditions that plaintiff experienced in connection with the contraband watch, including twenty-four hour lighting and mattress deprivation, violated the Eighth Amendment. The panel also concluded that plaintiff could not claim a liberty interest under the Due Process Clause of the Fourteenth Amendment, and it was not clearly established that he had sustained a violation of a state-created liberty interest. Therefore, both prison officials were entitled to qualified immunity. Concurring, District Judge Graham wrote separately because he disagreed with the majority’s interpretation of the Supreme Court’s decision in Sandin v. Conner, 515 U.S. 472 (1995), in the context of their analysis of plaintiff’s due process claim based on a state-created liberty interest. Dissenting in part, Judge Berzon agreed that prison officials were entitled to qualified immunity on the due process issues. Judge Berzon dissented because in her view, a reasonable officer would have known that, in combination, the twenty-four-hour bright light, the absence of a mattress, and the extensive bodily restraints risked depriving plaintiff of sleep, in violation of the Eighth Amendment.
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