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South Dakota Statutory Provisions, Immunity Preclude Prisoners' Alleged Unauthorized Sanction Claims
South Dakota state prisoners Leander Clay, James Smith and Kenneth Muetze (plaintiffs) appealed the dismissal of their pro se action for statutory immunity against South Dakota State Penitentiary and Department of Corrections personnel (defendants), which alleged unlawful disciplinary sanctions. The judgment was affirmed on appeal for other reasons.
The plaintiffs' lawsuit for declaratory judgment came after they were sanctioned for "major infractions" of prison rules. The suit alleged violations for the closing of the law library, removal of computers/word processors, loss of personal property from their cells, and money taken from their prison accounts. The plaintiffs argued that no administrative rules allowed such sanctions and they were therefore "without authority of law." The defendants' summary judgment motion was granted and the plaintiffs appealed, claiming that the circuit court had erred in not holding a hearing prior to dismissing the case.
The Supreme Court of South Dakota held that statutory provisions authorized the sanctions, and that res judicata and collateral estoppel barred the plaintiffs from raising the law library and computer/word processor claims because Smith had argued such claims in prior litigation. The Court further held that the plaintiffs failed to raise any issue of fact or allege that oral argument would have aided in a hearing prior to dismissal. The circuit court’s dismissal of the case was affirmed. See: Clay v. Weber, 733 N.W.2d 278 (S.D., 2007).
The plaintiffs' lawsuit for declaratory judgment came after they were sanctioned for "major infractions" of prison rules. The suit alleged violations for the closing of the law library, removal of computers/word processors, loss of personal property from their cells, and money taken from their prison accounts. The plaintiffs argued that no administrative rules allowed such sanctions and they were therefore "without authority of law." The defendants' summary judgment motion was granted and the plaintiffs appealed, claiming that the circuit court had erred in not holding a hearing prior to dismissing the case.
The Supreme Court of South Dakota held that statutory provisions authorized the sanctions, and that res judicata and collateral estoppel barred the plaintiffs from raising the law library and computer/word processor claims because Smith had argued such claims in prior litigation. The Court further held that the plaintiffs failed to raise any issue of fact or allege that oral argument would have aided in a hearing prior to dismissal. The circuit court’s dismissal of the case was affirmed. See: Clay v. Weber, 733 N.W.2d 278 (S.D., 2007).
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Related legal case
Clay v. Weber
| Year | 2007 |
|---|---|
| Cite | 733 N.W.2d 278 (S.D., 2007) |
| Level | State Supreme Court |
| Injunction Status | N/A |