Mackey v. Bloomfield

Summary

The United States District Court for the Northern District of California granted Defendant Della Baker’s motion for summary judgment in a prisoner’s 42 U.S.C. § 1983 due process action. The court held that inaccuracies in an MDO form, which incorrectly identified prior convictions, did not cause the plaintiff’s parole denial or otherwise result in an atypical and significant hardship. The court also denied the defendant’s motion to strike the plaintiff’s sur-reply.

Holdings

1. The inaccurate MDO form did not violate Mackey's due-process rights because the record contained no evidence that the form was used in his parole determination, caused an adverse consequence, or subjected him to an atypical and significant hardship.
2. Mackey failed to present a triable issue because he did not allege or provide evidence that Baker participated in, prepared, or controlled the records containing the alleged gang-member label.

Questions Presented

1. Whether Baker's inaccurate entries on an MDO form violated Mackey's Fourteenth Amendment right to procedural due process.
2. Whether the inaccurate MDO information caused or contributed to Mackey's 2021 parole denial or otherwise imposed an atypical and significant hardship.
3. Whether Mackey presented a triable due-process claim based on an alleged gang-member label.

Disposition

other