Hardaway v. Meyerhoff

Dist. Ct. did not err in granting on grounds of qualified immunity defendants-prison officials’ motion for summary judgment in plaintiff-prisoner’s section 1983 action alleging that defendants’ imposition of 182-day segregation term as sanction for prison forgery charge against plaintiff that was later overturned by Ill. Administrative Review Bd. violated plaintiff’s liberty interests under 14th Amendment. Instant 182-day confinement, that allowed plaintiff to have weekly shower and recreational yard visits, was insufficient to establish 14th Amendment violation as “atypical and significant hardship.” Moreover, plaintiff failed to identify any case law in existence at time of confinement that established that instant confinement implicated any liberty interest.