Figgs v. Dawson

Dist. Ct. did not err in granting defendant-warden’s motion for summary judgment in plaintiff-former prisoner’s section 1983 action alleging that warden and other prison officials violated his 8^th Amendment rights by being deliberately indifferent to possibility that he was being held beyond actual release date for his murder conviction, where record showed that plaintiff had served his full sentence by some months at time defendant-record officer supervisor recalculated defendant’s sentence following Prison Review Board’s vacatur of its November 1993 order finding that defendant had violated term of his MSR at time defendant had committed murder. While record showed that certain prison officials held mistaken belief that defendant had violated term of his MSR, which, in turn, had increased length of his sentence, plaintiff had failed to show that warden was deliberately indifferent to plaintiff’s custody status, where: (1) warden was not responsible for calculating plaintiff’s release date; and (2) warden took steps to refer issue to others, who were responsible for calculating said release date. However, Dist. Ct. erred in granting similar motion for summary judgment filed by defendant-record officer supervisor, where said defendant: (1) failed to review all relevant documents in plaintiff’s master file that could have cleared up misconception that defendant had two additional years added to his sentence; and (2) failed to send relevant documents to others who were investigating issue of plaintiff’s sentence. Also, said defendant’s reliance on previous sentence miscalculation did not constitute step taken to verify its accuracy.