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Tennessee: Punitive-Based Administrative Segregation States Claim

In this case involving the appeal of a disciplinary ruling, the Tennessee
Court of Appeals held that because a prisoner's placement in
administrative segregation appeared to be punitive, his petition for
common law writ of certiorari stated a claim.

Eric Woodruff, a prisoner at the Riverbend Maximum Security Institution in
Nashville, was issued disciplinary tickets for possession of contraband
and interfering with a guard's duties. Woodruff was ultimately found
guilty on both charges. For the possession of contraband charge, Woodruff
was sentenced to 20 days in punitive segregation and fined $4.00. For
interfering with a guard's duties, the disciplinary board fined Woodruff
$4.00 and recommended to the warden that he be placed in administrative

After his appeal to the warden was denied, Woodruff filed a petition for
common law writ of certiorari in the Davidson County Chancery Court,
alleging his placement in administrative segregation violated his due
process and equal protection rights. The Tennessee Department of
Correction (TDOC) moved for dismissal pursuant to Tenn.R.Civ.P., Rule 12.02
(6) for failure to state a claim, which the trial court granted. Woodruff

On August 28, 2002, the Tennessee Court of Appeals affirmed in part,
reversed in part and remanded. The appeals court first noted that
prisoners have no liberty interest in avoiding placement in administrative
segregation (which is non-punitive and based on "reasons of security,
safety, and prison management..."). Therefore, Woodruff's claim that the
board violated TDOC policy by failing to provide him with written notice
of the reasons for administrative segregation did not state a claim.
However, that complaint did raise another concern -- the basis for his
segregation. According to the Court of Appeals, Tennessee courts "have
long recognized grounds for grant of (common law writ of certiorari) 'if
the board has exceeded its jurisdiction, or has otherwise acted
unlawfully, arbitrarily or fraudulently.'" In the instant case,
administrative segregation was not an option for a disciplinary violation
under TDOC policy. Moreover, the disciplinary board may only recommend
administrative segregation -- it is solely the warden's duty to place a
prisoner in administrative segregation.

In Woodruff's case the only evidence that it was the warden's decision to
place him in administrative segregation was the warden's response to
Woodruff's appeal, which stated, After careful review, I find no reason
to change the disposition, charge, or the punishment imposed." Since the
TDOC provided no administrative record in the matter, the appellate court
held the TDOC "has provided neither the trial court nor this court any
indication that the administrative segregation Mr. Woodruff was subjected
to was for any reason other than as punishment, [and] we conclude that Mr.
Woodruff has stated a claim for relief...." This case was not reported in
S.W.3d. See: Woodruff v. Tennessee Department of Correction, Case No.
M2001-00494-COA-R3-CV (Tenn. Ct. App. 2002).

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Related legal case

Woodruff v. Tennessee Department of Corrections