Brown v. Oregon Dept. of Corr., No. 11-35628 (9th Cir. 2014)
Annotate this CasePlaintiff, currently incarcerated at SRCI, filed suit pro se under 42 U.S.C. 1983, alleging that prison officials violated his due process rights by housing him in the Intensive Management Unit (IMU) for twenty-seven months without periodic, meaningful review of his status. The court concluded that plaintiff's conditions of confinement in the IMU implicated a protected liberty interest under any plausible baseline. Nonetheless, the court concluded that plaintiff's claims against the Oregon Department of Corrections and his damages claims against the individual defendants in their official capacities were barred by the Eleventh Amendment. Plaintiff's remaining damages claims were barred by qualified immunity. The court affirmed the district court's grant of summary judgment on plaintiff's claim for declaratory relief because the record showed that plaintiff had been released from the IMU and there was no evidence that he was likely to again be subject to the challenged conditions.
Court Description: Prisoner Civil Rights. The panel affirmed the district court’s summary judgment in favor of prison officials in a 42 U.S.C. § 1983 action in which a prisoner alleged that officials violated his due process rights by housing him in the Intensive Management Unit without periodic, meaningful review of his status. The panel held that plaintiff’s twenty-seven month confinement in the Intensive Management Unit, without a meaningful review, imposed an atypical and significant hardship that implicated a protected liberty interest which gave rise to the procedural protections of the Due Process Clause. The panel also held, however, that plaintiff’s claims against the Oregon Department of Corrections and his damages claims against the individual defendants in their official capacities were barred by the Eleventh Amendment. Plaintiff’s remaining damages claims were barred by qualified immunity because, although a lengthy confinement without meaningful review may constitute atypical and significant hardship, the panel could not hold defendants liable for the violation of a right that was not clearly established at the time the violation occurred. The panel affirmed the district court’s summary judgment on plaintiff’s claim for declaratory relief because the record showed that he had been released from the Intensive Management Unit and there was no evidence that he was likely to again be subject to the challenged conditions.
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