Summary
This United States District Court for the Eastern District of Wisconsin decision grants the defendants' motion for summary judgment and dismisses the plaintiff's Fourteenth Amendment due process claim. The court found that the plaintiff's 30-day disciplinary segregation at a correctional facility did not impose an "atypical and significant hardship" sufficient to trigger a protected liberty interest under prevailing Seventh Circuit precedent. Consequently, the court determined that no constitutional due process violation occurred and denied the plaintiff's associated motions for an evidentiary hearing and sanctions.
Topics
Practice areas
Questions Presented
- Whether a 30‑day disciplinary segregation imposes a protected liberty interest under the Fourteenth Amendment due process clause
- Whether the plaintiff is entitled to summary judgment on his due‑process claim
Holdings
- A 30‑day disciplinary segregation does not constitute an atypical and significant hardship and therefore does not create a protected liberty interest for a prisoner.
- Summary judgment is proper because the plaintiff failed to demonstrate a deprivation of a protected liberty interest and therefore cannot establish the elements of his Fourteenth Amendment claim.
Key quotations
“The Fourteenth Amendment prohibits the states from depriving “any person of life, liberty, or property, without due process of law.”” (at 1)
“Plaintiff’s 30‑day confinement, in other words, was identical to everyone else who was on disciplinary segregation for violating prison rules; and it, therefore, was not an “atypical and significant hardship” in relation to the ordinary incidents of prison life.” (at 1)
Factual background
Plaintiff, an inmate at Redgranite Correctional Institution, received two conduct reports for alleged threats and disrespect. He served 30 days of disciplinary segregation. He alleged that the segregation and related conditions deprived him of a liberty interest without adequate procedural safeguards.
Procedural history
Plaintiff filed a civil rights action alleging a Fourteenth Amendment due‑process violation arising from two conduct reports and 30 days of disciplinary segregation. Defendants moved for summary judgment, which the court granted, dismissing the case. Plaintiff's motion for an evidentiary hearing and sanctions was denied.