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Sixth Circuit: “Security Threat Group” Designation Does Not Warrant Due Process Protections
In 2005, the Sixth Circuit Court of Appeals affirmed a district court's rulings against Michigan prisoner Keith Harbin-Bey, who in 2003 had filed a pro se civil rights lawsuit pursuant to 42 U.S.C. § 1983 alleging that, in designating him a member of a Security Threat Group (STG) without first affording him a hearing where he could contest the designation, prison officials violated his constitutional rights.
Applying the rational-basis test to Harbin-Bey's equal protection claim, the Court found that it was not arbitrary to afford hearings to prisoners prior to designating them as "escape risks" or "homosexual predators" but not prior to designating them as STG members. The Court also found that STG designation was not sufficiently adverse to warrant due process protections.
The Court similarly dispensed with Harbin-Bey's claims that prison officials (1) violated his right to access to the courts, (2) infringed upon his First Amendment right to receive periodicals, and (3) retaliated against him for filing grievances. See: Harbin-Bey v. Rutter, 420 F.3d 571 (6th Cir. 2005).
Applying the rational-basis test to Harbin-Bey's equal protection claim, the Court found that it was not arbitrary to afford hearings to prisoners prior to designating them as "escape risks" or "homosexual predators" but not prior to designating them as STG members. The Court also found that STG designation was not sufficiently adverse to warrant due process protections.
The Court similarly dispensed with Harbin-Bey's claims that prison officials (1) violated his right to access to the courts, (2) infringed upon his First Amendment right to receive periodicals, and (3) retaliated against him for filing grievances. See: Harbin-Bey v. Rutter, 420 F.3d 571 (6th Cir. 2005).
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Related legal case
Harbin-Bey v. Rutter
| Year | 2005 |
|---|---|
| Cite | 420 F.3d 571 (6th Cir. 2005) |
| Level | Court of Appeals |
| Conclusion | Bench Verdict |
| Injunction Status | N/A |