Billy Dean Smith and Jacob Lee Anagick v. State of Alaska, Department of Corrections

Summary

The Alaska Supreme Court affirmed summary judgment for the Alaska Department of Corrections and its officials in claims brought by two prisoners who lost prison-industry jobs after being placed in administrative segregation during an escape investigation. The court held that, even assuming the prisoners had a protected interest in their jobs under Alaska’s constitutional rehabilitation provision, the administrative-segregation hearings satisfied applicable due process requirements. The court also upheld the superior court’s procedural rulings and its conclusions concerning the prisoners’ other constitutional claims and qualified immunity.

Holdings

1. Even assuming the prisoners had a protected liberty or property interest in their laundry jobs under Ferguson v. State, Department of Corrections, the administrative-segregation classification hearings provided all process constitutionally required before the prisoners were removed from those jobs.
2. The Sixth Amendment confrontation right does not apply to civil administrative-segregation or job-termination proceedings.
3. The superior court did not abuse its discretion by declining to instruct or permit amendment to add negligent-training, breach-of-contract, or spoliation claims because the proposed claims were unsupported, legally insufficient, or moot.
4. The superior court did not abuse its discretion by denying the motion to consolidate this case with Smith v. Busby.

Questions Presented

1. Whether the prisoners received constitutionally adequate procedural due process before losing their Prison Industries laundry jobs as a consequence of administrative segregation.
2. Whether the prisoners' Sixth Amendment confrontation claim applied to the administrative-segregation and job-termination proceedings.
3. Whether the superior court abused its discretion by failing to instruct or permit the pro se prisoners to amend their complaint to add negligent-training, breach-of-contract, and spoliation claims.
4. Whether the superior court abused its discretion by denying the prisoners' motion to consolidate this case with Smith v. Busby.

Disposition

affirmed