Vidal v. Venettozzi

Summary

The United States Court of Appeals for the Second Circuit considers whether Joseph Vidal’s disciplinary segregation in a special housing unit implicated a protected liberty interest under the Fourteenth Amendment. The court holds that the duration of his disciplinary segregation constituted an atypical and significant hardship based on duration alone, triggering procedural due process protections. It vacates the district court’s summary judgment and remands for further proceedings.

Holdings

1. Vidal's disciplinary segregation constituted an atypical and significant hardship in relation to the ordinary incidents of prison life and therefore implicated a protected liberty interest under the Fourteenth Amendment.
2. The duration of Vidal's disciplinary segregation alone was sufficient to trigger a protected liberty interest, regardless of whether the relevant period was measured as 270 days imposed, 258 days served in the SHU from the incident through the sentence, or 180 days actually served under the challenged sentence.
3. The district court's grant of summary judgment was vacated and the case was remanded for further proceedings.

Questions Presented

1. Whether Vidal's disciplinary segregation in the SHU constituted an atypical and significant hardship sufficient to implicate a protected liberty interest under the Fourteenth Amendment and Sandin v. Conner.
2. Whether the duration of Vidal's disciplinary segregation alone was sufficient to trigger procedural due process protections.
3. Whether the district court's summary judgment ruling should be vacated and the case remanded for consideration of qualified immunity and personal involvement issues not addressed below.

Disposition

reversed_and_remanded