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Damages for Improper Segregation Needs Resolution by Jury
The Second Circuit Court of Appeals held prison officials were entitled to a jury trial to determine damages caused by the failure to call witnesses at a disciplinary hearing. A prisoner at New York’s Attica Correctional Facility was charged with assault on a guard, found guilty at a disciplinary hearing, and sentenced to the Special Housing Unit (SHU) for 60 days. The prisoner exhausted his administrative remedies and filed an action in state court seeking release from SHU, restoration of good time, and expungement of the disciplinary proceedings from his prisoner file, which the defendants agreed to. The prisoner then filed the action alleging violation of his due process rights. The district court’s dismissal was reversed. See: Patterson v. Coughlin, 761 F.2d 886 (2d Cir. 1985), cert. denied, 474 U.S. 1100, 106 S. Ct. 879, 88 C. Ed. 20 916. On remand, the district court entered summary judgment for the prisoner and awarded him $5,300 for his 53 days of segregation. The defendants appealed.
The defendant argued the prisoner incurred no injury because he would have been found guilty even if his witnesses were called. The Second Circuit held the burden is on the prisoner plaintiff to show that the challenged disciplinary action would not have been taken if he had been allowed to present a defense. In this case, the Court found the prisoner presented adequate evidence to show that his requested prisoner witnesses would have contradicted the guard’s testimony, and they would have stated the prisoner had merely broken up the fight between them and had nothing to do with the assault on the guard. The Court rejected the defendant’s position that the hearing officer would have rejected the witnesses’ testimony. The Court said the prisoner is entitled to an impartial decision maker who does not say how he would assess evidence he has not yet seen.
The Court further held the defendants are entitled to a jury trial on the issue of damages. See: Patterson v. Coughlin, 905 F.2d 564 (2d Cir. 1990).
The defendant argued the prisoner incurred no injury because he would have been found guilty even if his witnesses were called. The Second Circuit held the burden is on the prisoner plaintiff to show that the challenged disciplinary action would not have been taken if he had been allowed to present a defense. In this case, the Court found the prisoner presented adequate evidence to show that his requested prisoner witnesses would have contradicted the guard’s testimony, and they would have stated the prisoner had merely broken up the fight between them and had nothing to do with the assault on the guard. The Court rejected the defendant’s position that the hearing officer would have rejected the witnesses’ testimony. The Court said the prisoner is entitled to an impartial decision maker who does not say how he would assess evidence he has not yet seen.
The Court further held the defendants are entitled to a jury trial on the issue of damages. See: Patterson v. Coughlin, 905 F.2d 564 (2d Cir. 1990).
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Related legal case
Patterson v. Coughlin
| Year | 1990 |
|---|---|
| Cite | 905 F.2d 564 (2d Cir. 1990) |
| Level | Court of Appeals |