Steven Gunn v. Mrs. Bublitz, et al.

Summary

The United States District Court for the Eastern District of Missouri dismissed Steven Gunn’s 42 U.S.C. § 1983 complaint without prejudice under 28 U.S.C. § 1915A for failure to state a claim. The court held that Gunn’s two-month placement in administrative segregation did not implicate a protected liberty interest under the Due Process Clause and denied his pending motions as moot.

Holdings

1. A prisoner's placement in administrative segregation does not implicate a protected liberty interest absent facts showing an atypical and significant hardship in relation to the ordinary incidents of prison life. Gunn's alleged two-month placement did not establish such a deprivation, so the due process protections he claimed were not applicable.
2. Because Gunn failed to allege deprivation of a protected liberty interest, the procedures used at the classification hearing could not support a due process claim. The complaint therefore failed to state a claim upon which relief could be granted.
3. Because the administrative classification hearing was not a criminal prosecution, Gunn was not entitled to the full array of constitutional rights afforded to criminal defendants, including the criminal beyond-a-reasonable-doubt standard.

Questions Presented

1. Whether Gunn's two-month placement in administrative segregation deprived him of a protected liberty interest sufficient to trigger Fourteenth Amendment due process protections.
2. Whether Gunn stated a due process claim based on the alleged failure to provide a fair and impartial hearing, assistance in preparing a defense, or proof beyond a reasonable doubt.
3. Whether Gunn's motions for in forma pauperis status, appointment of counsel, an evidentiary hearing, and discovery should be granted after dismissal of the complaint.

Disposition

dismissed