Summary
The Massachusetts Supreme Judicial Court held that a putative class action challenging the placement of prisoners in nondisciplinary administrative segregation was not moot merely because the named plaintiffs were no longer confined in special management units. The court held that the Superior Court had erred in dismissing the amended complaint based on an overbroad interpretation of LaChance v. Commissioner of Correction and remanded for further proceedings. The decision addresses due process, prison classification procedures, Department of Correction regulations, and class-action practice.
Topics
Practice areas
Questions Presented
- Whether the appeal became moot when none of the named plaintiffs remained confined in a special management unit.
- Whether LaChance v. Commissioner of Correction resolved all of the plaintiffs' regulatory and constitutional claims and justified dismissal of the amended complaint without adjudicating the class-certification motion.
- Whether prisoners confined in special management units under conditions substantially similar to departmental segregation units may pursue claims for application of the Department of Correction's departmental segregation unit regulations and their associated procedural protections and privileges.
Holdings
- The appeal was not moot because the case was brought as a putative class action and the class allegations remained operative until a judge considered and rejected them on their merits.
- LaChance did not resolve all of the plaintiffs' claims and did not overrule Haverty or related decisions requiring application of the departmental segregation unit regulations to prisoners confined in conditions substantially similar to those of a departmental segregation unit.
- The plaintiffs were entitled to pursue their motion for class certification and, on the merits, their claims that prisoners confined in SMUs are entitled to application of the departmental segregation unit regulations and the procedural protections and other rights included in those regulations.
Key quotations
“It is not moot because the plaintiffs brought this case as a putative class action, and the class action allegations contained in the amended complaint remain operative until a judge has considered and rejected them on their merits.” (at 755-756)
“Because LaChance I did not overrule Haverty, the plaintiffs are entitled to pursue in the Superior Court their motion to certify a class, and, on the merits, their claims that as prisoners confined to SMUs, they are entitled to have the DSU regulations applied to them and entitled to all the procedural protections and other rights included within those regulations.” (at 763-764)
Factual background
The named plaintiffs were Massachusetts prisoners who had been placed for varying periods in special management units in nondisciplinary administrative segregation. The SMU conditions involved confinement in individual cells for twenty-three hours per day, severe restrictions on recreation, visitation, canteen purchases, employment, education, treatment, religious services, and other privileges. The plaintiffs alleged that these conditions violated their State and Federal due process rights and Department of Correction regulations because they were not afforded the procedural protections required for prisoners held in department segregation unit-like conditions.
Procedural history
The plaintiffs filed a civil action in the Superior Court in January 2012 challenging their confinement in special management units and seeking class certification, declaratory relief, and injunctive relief. The Superior Court denied class certification and dismissed the amended complaint after concluding that LaChance v. Commissioner of Correction resolved the claims. The Appeals Court dismissed the appeal as moot because no named plaintiff remained in an SMU. The Supreme Judicial Court reversed and remanded.
Remand instructions
The case was remanded to the Superior Court for further proceedings consistent with the opinion, including consideration of the plaintiffs' motion for class certification and adjudication of the merits of their regulatory and constitutional claims.