Alston v. Cahill
To prove a procedural due-process violation, a prisoner must establish he possesses a protected liberty interest of which he was deprived without the required process. Officials placed the plaintiff prisoner in punitive segregation, because he allegedly fought with correction officers. At disciplinary hearings, he was found guilty of assaulting correction officers. Additional infractions extended the punitive segregation. Eventually, officials placed the plaintiff in administrative segregation, after a hearing on whether his presence in the general prison population constituted a security threat. The plaintiff remained in administrative segregation for several years, because he continued to accumulate disciplinary reports. The plaintiff sued, alleging the defendants violated his 14th Amendment due-process rights by conducting an untimely administrative segregation hearing, failing to provide sufficient notice and failing to conduct meaningful reviews of his administrative segregation. Several courts have held that Connecticut prisoners lack a liberty interest in their classifications, partly because Department of Correction directives provide discretion to the DOC with respect to placement in administrative segregation. The court found that prisoners possess an expectation that they will not be confined to administrative segregation in the absence of certain predicates. The plaintiff, who likely possessed a protected liberty interest, received all the process owed under the Constitution. The plaintiff was informed about incidents that led to consideration of administrative segregation and permitted the opportunity to rebut. A prison warden reviewed the plaintiff's status regularly. Even if the plaintiff's rights were violated, qualified immunity protected individual defendants. On the plaintiff's Batson challenge, although the defendants, the majority of whom are African American, used a peremptory challenge to strike Juror 622, the only African-American juror who remained on the panel, the court credited Assistant Attorney General Terrence O'Neill's concern that Juror 622, who worked with trouble youth, potentially could be biased against law enforcement. The plaintiff established a prima facie case of race discrimination. The defendants rebutted with a race-neutral basis to strike Juror 622. The court denied the motion for a mistrial on First Amendment retaliation, Eighth Amendment and assault claims that were tried to the jury. The court granted the defendants' motion for judgment.