Inmate filed complaint against 3 DOC officers, alleging they violated his procedural due process and failed to follow DOC regulations during his disciplinary proceedings. Revocation of Plaintiff's good conduct credits did not interfere with a liberty interest because Plaintiff is ineligible for release. Only sanctions which result in loss of good conduct time credits for inmates eligible for release on mandatory supervision or which otherwise directly and adversely affect release on mandatory supervision will impose upon a liberty interest. Failure to follow DOC regulation does not by itself create an independent right of action allowing an inmate to file suit in state court to compel a correctional officer to comply with the regulation. Thus, court properly dismissed complaint. (TURNER and HARRIS, concurring.)
Illinois Appellate Court
Civil Court
Due Process