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Tennessee Prisoners Have No Right to Specific Classification, Only the Determination Thereof
Tennessee State prisoner Davalon Higgins applied for work release at Middle Tennessee Correctional Center Annex (MTCC) in 2003 and was denied because his record indicated he was a member of a Security Threat Group (STG). His complaint alleging constitutional violations for due process and equal protection of law were dismissed. On appeal the dismissal was affirmed, but his allegations that the Tennessee Department of Corrections (TDOC) disregarded its own policies and procedures in labeling him a STG member were remanded to the Chancery Court for a ruling on a writ of certiorari.
An inquiry determined that Higgins' STG status was input by staff at the Shelby County Sheriff's Department in 1999 and were not based on prison or jail activity. Another entry showed him to be a member of the Crips gang. Higgins filed a § 1983 complaint against TDOC Commissioner Quenton White, MTCC Warden Holland and Shelby Co. Sheriff Luttrell for constitutional violations for labeling him a gang member without an opportunity for confrontation, for being treated differently than other prisoners, and for the TDOC's failure to follow its own policy.
The court held that under Sandin v. Conner, 515 U.S. 472, 115 S. Ct. 2293, 132 L.Ed.2d 418 (1995), the procedural safeguards of the due process clause can only be triggered by actions imposing an "atypical and significant hardship ... in relation to the ordinary incidents of prison life." The court also held that no prisoner is entitled to a specific security classification, denying the equal protection claim and granting White and Holland's motion to dismiss. Higgins filed a motion for reconsideration, which was denied, and summary judgment was granted to Luttrell.
On appeal, all claims involving White, Holland and Luttrell were dismissed. To determine whether the defendants acted illegally, arbitrarily or fraudulently in Higgins being labeled as a STG member, the case was remanded to the Chancery Court to hold a hearing with the complete record to decide if a writ of certiorari should be issued. See: Higgins v. White, Tenn. Court of Appeals, Case No. 2004 00412 COA R3 CV (June 27, 2006), 2006 WL 1763648.
An inquiry determined that Higgins' STG status was input by staff at the Shelby County Sheriff's Department in 1999 and were not based on prison or jail activity. Another entry showed him to be a member of the Crips gang. Higgins filed a § 1983 complaint against TDOC Commissioner Quenton White, MTCC Warden Holland and Shelby Co. Sheriff Luttrell for constitutional violations for labeling him a gang member without an opportunity for confrontation, for being treated differently than other prisoners, and for the TDOC's failure to follow its own policy.
The court held that under Sandin v. Conner, 515 U.S. 472, 115 S. Ct. 2293, 132 L.Ed.2d 418 (1995), the procedural safeguards of the due process clause can only be triggered by actions imposing an "atypical and significant hardship ... in relation to the ordinary incidents of prison life." The court also held that no prisoner is entitled to a specific security classification, denying the equal protection claim and granting White and Holland's motion to dismiss. Higgins filed a motion for reconsideration, which was denied, and summary judgment was granted to Luttrell.
On appeal, all claims involving White, Holland and Luttrell were dismissed. To determine whether the defendants acted illegally, arbitrarily or fraudulently in Higgins being labeled as a STG member, the case was remanded to the Chancery Court to hold a hearing with the complete record to decide if a writ of certiorari should be issued. See: Higgins v. White, Tenn. Court of Appeals, Case No. 2004 00412 COA R3 CV (June 27, 2006), 2006 WL 1763648.
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Related legal case
Higgins v. White
| Year | 2006 |
|---|---|
| Cite | Tenn. Court of Appeals, 2006 WL 1763648. |
| Level | State Court of Appeals |
| Injunction Status | Granted |