Ciampi v. Commissioner of Correction

Summary

The Massachusetts Supreme Judicial Court considered whether the Department of Correction had statutory authority to impose restitution as a prison disciplinary sanction and to withdraw funds from an inmate’s account to satisfy that sanction. The court held that restitution was within the Commissioner of Correction’s broad authority to maintain prison discipline and that the withdrawal did not violate the inmate’s protected property interest because he received constitutionally adequate notice and process. The court vacated the grant of summary judgment for the inmate and directed that summary judgment enter for the defendants.

Holdings

1. The Commissioner of Correction's broad statutory authority to maintain safety, security, order, and discipline in correctional facilities includes authority to promulgate regulations authorizing restitution as a disciplinary sanction and permitting the withdrawal or impoundment of inmate-account funds to satisfy that sanction.
2. Assuming that Massachusetts law creates a protected property interest in funds held in a prison account, Ciampi received all process constitutionally required before the funds were withdrawn because he received advance written notice, an opportunity to present a defense, a written statement of the evidence and reasons for the sanction, and appellate review within the prison disciplinary process.

Questions Presented

1. Whether the Commissioner of Correction had statutory authority to promulgate regulations and policies authorizing restitution as a prison disciplinary sanction and permitting deductions from an inmate's account to satisfy that sanction.
2. Whether withdrawing funds from Ciampi's prison account to satisfy the restitution sanction violated a statutorily protected property interest or procedural due process.

Disposition

reversed