Michael Matzell v. Anthony J. Annucci

Summary

The Second Circuit held that New York prison officials were entitled to qualified immunity on an Eighth Amendment claim for denying a prisoner judicially ordered enrollment in the Shock Incarceration Program because it was not clearly established that such denial violated the Eighth Amendment. However, the court denied qualified immunity on a Fourteenth Amendment substantive due process claim, finding that the officials plausibly violated a clearly established right by administratively altering the sentencing court's order, thereby extending the prisoner's confinement, contrary to N.Y. Penal Law § 60.04(7) and N.Y. Correction Law § 867(2-a). The decision affirms that prison officials may not disregard a judicial order mandating enrollment in a program that offers early release, and that existing precedent (e.g., *Earley v. Murray*, *Vincent v. Yelich*) clearly established that officials lack power to modify a sentence.

Holdings

1. Defendants are entitled to qualified immunity on the Eighth Amendment claim because it was not clearly established at the time that denying a prisoner the opportunity for early release through Shock would violate the Eighth Amendment.
2. Defendants are not entitled to qualified immunity on the Fourteenth Amendment claim because Matzell plausibly alleged a violation of clearly established substantive due process rights.

Questions Presented

1. Whether defendants are entitled to qualified immunity on the Eighth Amendment claim for denying judicially ordered Shock enrollment.
2. Whether defendants are entitled to qualified immunity on the Fourteenth Amendment substantive due process claim for denying judicially ordered Shock enrollment.

Disposition

affirmed_in_part_reversed_in_part_remanded