Dist. Ct. did not err in granting defendants-police officials’ motion for summary judgment in plaintiff-prisoners’ section 1983 action alleging that defendants violated his 8th Amendment rights by placing him in solitary confinement for 10-year period beginning in 2006 based upon 1990 prison incident in which plaintiff killed guard dog and stabbed two correctional officers. Plaintiff’s complaints about his prison cell, which pertained to lighting, food, temperatures, sleeping arrangements, restricted time for showers and exercise, did not rise to level of extreme deprivation of basic human needs to satisfy 8th Amendment standards. Moreover, plaintiff had opportunities to participate in programs to transition into prison general population. Dist. Ct. erred, though, in granting defendants’ summary judgment motion with respect to plaintiff’s due process claim in which plaintiff contended that defendant’s rote denial of 30-day administrative reviews of his solitary confinement status denied him due process. Record contained triable issue as to whether said reviews were meaningful, where: (1) defendants used in series of denials same uninformative language that provided no explanation as to why continued placement in solitary confinement was necessary; (2) defendant had long stretches in which he had no serious disciplinary problem; and (3) record contained dispute as to whether instant reviews took into account any updated circumstances in evaluating need for continued solitary confinement.
Federal 7th Circuit Court
Civil Court
Due Process