Summary
This Seventh Circuit opinion reviews a district court's grant of summary judgment for prison officials in a § 1983 action brought by an incarcerated plaintiff alleging deprivation of a liberty interest through prolonged disciplinary segregation under unsanitary conditions. The court holds that while the plaintiff raised a genuine issue of material fact regarding whether his three-month solitary confinement combined with deplorable conditions constituted an atypical and significant hardship triggering due process protections, the defendants are entitled to qualified immunity because the applicable law was not clearly established at the time. Consequently, the court affirms the district court's judgment in favor of the defendants.
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Practice areas
Questions Presented
- Whether the combination of three months in disciplinary segregation and allegedly appalling conditions created a genuine issue of fact as to whether Jackson was deprived of a protected liberty interest under the Fourteenth Amendment.
- Whether the defendants violated clearly established law, thereby defeating qualified immunity, by imposing three months of disciplinary segregation without permitting Jackson to call witnesses or view video evidence.
- Whether the procedures provided at Jackson's disciplinary hearing were constitutionally adequate.
Holdings
- Under Sandin, Wilkinson, and Seventh Circuit precedent, the duration and conditions of disciplinary segregation must be considered together. Jackson's evidence of three months in allegedly disgusting and unsanitary conditions was sufficient to permit a reasonable jury to find an atypical and significant hardship and a protected liberty interest.
- The defendants were entitled to qualified immunity because, as of March 2020, it was not clearly established that three months of disciplinary segregation under conditions similar to Jackson's implicated a protected liberty interest.
- The court did not decide whether Jackson received all process constitutionally due because qualified immunity resolved the claim.
Key quotations
“We must therefore analyze “the combined import of the duration of the segregative confinement and the conditions endured by the prisoner during that period” to determine whether solitary confinement deprives a prisoner of a liberty interest warranting due process protections.” (11)
“A reasonable jury could conclude that the combined effects of Jackson’s three-month assignment to disciplinary segregation and the conditions of his segregation imposed what Sandin called “an atypical and significant hardship.”” (17)
“Moving forward, such short terms of solitary confinement combined with comparable disgusting conditions will suffice to show a loss of protected liberty requiring procedural protections, as will longer terms of solitary confinement alone.” (22)
Factual background
While incarcerated at Stateville Correctional Center, Abre Jackson became involved in a physical altercation with correctional officers after an officer approached his cell to close the chuckhole. Jackson alleged that officers struck or bent his fingers and that Marc Anastacio sprayed him with a chemical agent. Following a disciplinary ticket and hearing at Pontiac Correctional Center, Jackson was sentenced to three months of disciplinary segregation. Jackson presented evidence that the segregation unit had feces and urine on cell walls, constant banging and noise, contaminated water, and roaches and mice, conditions he claimed were substantially worse than those in general population.
Procedural history
After a prison disciplinary hearing, Jackson was sentenced to three months of disciplinary segregation. He sued under § 1983, alleging that the disciplinary proceedings violated the Fourteenth Amendment because he was not allowed to call witnesses or view video evidence. The Northern District of Illinois granted summary judgment for defendants on the ground that Jackson had not shown a protected liberty interest. The Seventh Circuit disagreed with that merits conclusion but affirmed because defendants were entitled to qualified immunity.