David Williams is no angel. While serving time for murder, he was convicted of killing another prisoner.
Over the course of the next 17 years, though, Williams pretty much stayed out of trouble. He had minor disciplinary infractions but none that involved violence.
Nevertheless, in June 1999, Williams was placed in ad seg after returning to the Arkansas Department of Corrections (ADOC) following a three-year stint in a Utah prison pursuant to an interstate compact agreement.
ADOC rules require annual classification reviews for prisoners held in ad seg. The reviews are supposed to assess whether the prisoner would pose a “serious threat to life, property, self, staff, or other inmates” if released to the general population.
More importantly, though, the Eighth Circuit had held that such classification reviews must be “meaningful” and not focus on the prisoner’s “past conduct in reviewing his ongoing ad seg status.” See: Williams v. Norris, 277 Fed.Appx. 647, 650 (8th Cir. 2008).
However, Arkansas prison officials just couldn’t get the fact that Williams had killed another prisoner out of their minds. Each year they refused to release him into the general population, asserting he was a security threat.
Williams sued claiming violation of his due process rights. Following a bench trial, the district court ruled in his favor on June 14, 2010.
“The Court finds in this case that defendants improperly relied on the plaintiff’s distant past in rendering their decision to retain him in ad seg, and failed to support their belief that he was a continuing threat by setting forth specific reasons for their decisions,” the district court wrote.
In so holding, the court noted that the defendants had “presented no specific documentary evidence to support their continued conclusions that plaintiff was a threat to the security and good order of the institution.”
As such, the district court concluded that the annual reviews Williams received “were not ‘meaningful’ and therefore, that plaintiff’s due process rights were violated by his continued incarceration in [ad seg] from 1999-2009.”
The court awarded Williams $4,846 in damages, which translates to $1.36 a day for the near-decade he spent in ad seg. Cross-appeals have since been filed and remain pending. See: Williams v. Norris, 721 F.Supp.2d 824 (E.D. Ark. 2010).
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Related legal case
Williams v. Norris
|Cite||721 F.Supp.2d 824 (E.D. Ark. 2010)|