Goodrick - Certified Question of Law
Annotate this CaseThe United States District Court for the District of Idaho certified a question of law to the Idaho Supreme Court. Plaintiff was a prisoner in the custody of the Idaho Department of Correction (IDOC), currently incarcerated at the Idaho State Correctional Institution (ISCI). He asserts that he, and all IDOC prisoners, have a state-created liberty interest in being employed, arising from Idaho Code [section] 20-209. Plaintiff asserted the statute contained a "very specific, clear, and unambiguous" mandate that the Board of Correction must provide all inmates with employment during incarceration. The federal court asked the Idaho Supreme Court for guidance on plaintiff's contention: whether Idaho Code section 20-209 required the state board of correction to provide employment for all prisoners, and, if so, what was the minimum the board must do to implement the statute’s mandate? The Supreme Court responded, finding 20-209 required the Board to make employment available for all prisoners in the form of: (1) labor assignments as prescribed by the Board’s rules and regulations; and/or (2) implementation of statutory work programs managed by the Board in accordance with its rules and regulations. The Board retained discretion to manage these prisoner employment opportunities pursuant to its broad control over the correctional system. Section 20-209 did not create a right to paid or unpaid work during a prisoner’s period of incarceration or establish an employer-employee relationship between the Board and the prisoner. At a minimum, the Board must comply with legislation controlling its responsibilities managing prisoner employment and with its own rules and regulations.
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