Greenlee v. Vanihel

Summary

The court granted defendants' motion for summary judgment in Timothy Greenlee's 42 U.S.C. § 1983 action concerning his prolonged placement in disciplinary segregation at Wabash Valley Correctional Facility. The court held that Greenlee failed to show a clearly established Fourteenth Amendment due process or Eighth Amendment conditions-of-confinement violation sufficient to overcome qualified immunity. Claims against several remaining defendants were not resolved by this order.

Holdings

1. Defendants were entitled to summary judgment and qualified immunity on Greenlee's claim concerning his placement in disciplinary segregation because he did not show, under clearly established law, that the conditions of his segregation imposed an atypical and significant hardship or substantially deviated from ordinary prison conditions.
2. Defendants were entitled to summary judgment and qualified immunity on Greenlee's Eighth Amendment claim because he did not show that the secure-confinement conditions denied him the minimal civilized measures of life's necessities or that the asserted right was clearly established.
3. A nonmoving party's failure to respond does not automatically entitle the movant to summary judgment; the movant must still demonstrate that judgment is proper under the undisputed facts.

Questions Presented

1. Whether defendants were entitled to qualified immunity on Greenlee's Fourteenth Amendment procedural due-process claim concerning his placement in disciplinary segregation.
2. Whether defendants were entitled to qualified immunity on Greenlee's Eighth Amendment conditions-of-confinement claim concerning conditions in the secure confinement unit.
3. Whether defendants were entitled to summary judgment under Rule 56 based on the undisputed record and Greenlee's failure to respond.

Disposition

other