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Arkansas Prisoner’s Ad-Seg Reviews Held to be Meaningless; Case Remanded to Recalculate Damages
The Eighth Circuit Court of Appeals has upheld an Arkansas federal district court’s finding that state prison officials denied a prisoner meaningful reviews of his placement in administrative segregation, but ordered a recalculation of the lower court’s damage award.
The case involved Arkansas prisoner David Williams, who began serving a life sentence without parole in 1981. Just a year later he was convicted of killing another prisoner. He was released into general population after serving 18 months in administrative segregation (Ad Seg) at the Tucker Maximum Security Unit.
From 1983 to 1995, Williams served his sentence without any major violent incidents, but in 1995 he was assaulted by another prisoner. Prison officials believed the attack stemmed from Williams’ suspected “trafficking and trading” in drugs, and the incident may have resulted from a “drug deal gone bad.”
Ostensibly for his own protection, prison officials placed Williams in Ad Seg in December 1995. He remained there for nearly 14 years until March 13, 2009. His attacker served only 56 days in administrative segregation. In order to justify Williams’ lengthy stint in Ad Seg, which included a three-year transfer to the Utah Department of Corrections, prison officials repeatedly claimed he was “a threat to the security and good order of the institution.”
Williams filed a pro se civil rights complaint in the U.S. District Court for the Eastern District of Arkansas on February 16, 2005, that alleged that his due process and equal protection rights had been violated by his almost 14-year confinement in Ad Seg.
The court granted summary judgment to the defendants but the Eighth Circuit reversed in 2008. The appellate court found Williams had shown an atypical and significant hardship that entitled him to due process, and there was an unresolved fact issue as to whether he had received meaningful reviews of his Ad Seg status rather than rubber-stamped sham reviews. See: Williams v. Norris, 277 Fed.Appx. 647 (8th Cir. 2008).
On remand, the district court held a bench trial. It found “that the reviews conducted under the auspices of these defendants were not ‘meaningful’ and therefore, that [Williams’] due process rights were violated by his continued incarceration” in Ad Seg. Williams was awarded $4,846 – $1.00 in nominal damages for each day he remained in administrative segregation. [See: PLN, Nov. 2011, p.32].
In holding there was no error as to the due process violations, the Eighth Circuit pointed to the evidence. The appellate court noted that one of the prison official defendants had testified that “even if Williams proved to be ‘the perfect model citizen’ or ‘model prisoner,’ his vote ... would always be that Williams remain in Ad Seg in light of his transgressions.”
The Eighth Circuit said this is precisely the type of undue weight accorded to past facts that it explicitly prohibited in Kelly v. Brewer, 535 F.2d 394 (8th Cir. 1975) and the previous appeal in Williams’ case. The appellate court also found the Ad Seg reviews by prison officials “lacked the requisite meaningfulness because they failed to explain to Williams, with any reasonable specificity, why he constituted a continuing threat to security and good order of the institution.” While the Court of Appeals agreed with the defendants that their suspicion as to Williams’ dangerousness would have been material to continuing his placement in Ad Seg, their failure to appropriately document that rationale and convey it to Williams made the reviews unmeaningful.
Turning to the issue of damages, the Eighth Circuit found error in the district court’s per-day calculation. The proper method, the appellate court held, is a “per-constitutional-violation” analysis; the violation is not per day served in Ad Seg, but “the faulty 60-day Classification Committee hearings” that resulted in the denial of procedural due process.
Thus, according to the Court of Appeals, “Williams is entitled to no more than $1 for each procedurally defective Classification Committee hearing”; further, the district court did not err in declining to award compensatory or punitive damages.
The district court’s judgment was affirmed in all aspects except for the damage award, which was remanded to be recalculated. The defendants moved for rehearing en banc, which was denied on February 6, 2012; their petition for writ of certiorari to the U.S. Supreme Court was rejected on October 1, 2012. The case remains pending on remand to the district court for recalculation of Williams’ damage award. See: Williams v. Hobbs, 662 F.3d 994 (8th Cir. 2011), cert. denied.
The case involved Arkansas prisoner David Williams, who began serving a life sentence without parole in 1981. Just a year later he was convicted of killing another prisoner. He was released into general population after serving 18 months in administrative segregation (Ad Seg) at the Tucker Maximum Security Unit.
From 1983 to 1995, Williams served his sentence without any major violent incidents, but in 1995 he was assaulted by another prisoner. Prison officials believed the attack stemmed from Williams’ suspected “trafficking and trading” in drugs, and the incident may have resulted from a “drug deal gone bad.”
Ostensibly for his own protection, prison officials placed Williams in Ad Seg in December 1995. He remained there for nearly 14 years until March 13, 2009. His attacker served only 56 days in administrative segregation. In order to justify Williams’ lengthy stint in Ad Seg, which included a three-year transfer to the Utah Department of Corrections, prison officials repeatedly claimed he was “a threat to the security and good order of the institution.”
Williams filed a pro se civil rights complaint in the U.S. District Court for the Eastern District of Arkansas on February 16, 2005, that alleged that his due process and equal protection rights had been violated by his almost 14-year confinement in Ad Seg.
The court granted summary judgment to the defendants but the Eighth Circuit reversed in 2008. The appellate court found Williams had shown an atypical and significant hardship that entitled him to due process, and there was an unresolved fact issue as to whether he had received meaningful reviews of his Ad Seg status rather than rubber-stamped sham reviews. See: Williams v. Norris, 277 Fed.Appx. 647 (8th Cir. 2008).
On remand, the district court held a bench trial. It found “that the reviews conducted under the auspices of these defendants were not ‘meaningful’ and therefore, that [Williams’] due process rights were violated by his continued incarceration” in Ad Seg. Williams was awarded $4,846 – $1.00 in nominal damages for each day he remained in administrative segregation. [See: PLN, Nov. 2011, p.32].
In holding there was no error as to the due process violations, the Eighth Circuit pointed to the evidence. The appellate court noted that one of the prison official defendants had testified that “even if Williams proved to be ‘the perfect model citizen’ or ‘model prisoner,’ his vote ... would always be that Williams remain in Ad Seg in light of his transgressions.”
The Eighth Circuit said this is precisely the type of undue weight accorded to past facts that it explicitly prohibited in Kelly v. Brewer, 535 F.2d 394 (8th Cir. 1975) and the previous appeal in Williams’ case. The appellate court also found the Ad Seg reviews by prison officials “lacked the requisite meaningfulness because they failed to explain to Williams, with any reasonable specificity, why he constituted a continuing threat to security and good order of the institution.” While the Court of Appeals agreed with the defendants that their suspicion as to Williams’ dangerousness would have been material to continuing his placement in Ad Seg, their failure to appropriately document that rationale and convey it to Williams made the reviews unmeaningful.
Turning to the issue of damages, the Eighth Circuit found error in the district court’s per-day calculation. The proper method, the appellate court held, is a “per-constitutional-violation” analysis; the violation is not per day served in Ad Seg, but “the faulty 60-day Classification Committee hearings” that resulted in the denial of procedural due process.
Thus, according to the Court of Appeals, “Williams is entitled to no more than $1 for each procedurally defective Classification Committee hearing”; further, the district court did not err in declining to award compensatory or punitive damages.
The district court’s judgment was affirmed in all aspects except for the damage award, which was remanded to be recalculated. The defendants moved for rehearing en banc, which was denied on February 6, 2012; their petition for writ of certiorari to the U.S. Supreme Court was rejected on October 1, 2012. The case remains pending on remand to the district court for recalculation of Williams’ damage award. See: Williams v. Hobbs, 662 F.3d 994 (8th Cir. 2011), cert. denied.
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Related legal cases
Williams v. Hobbs
| Year | 2011 |
|---|---|
| Cite | 662 F.3d 994 (8th Cir. 2011), cert. denied. |
| Level | Court of Appeals |
| Conclusion | Bench Verdict |
| Injunction Status | N/A |
Williams v. Norris
| Year | 2008 |
|---|---|
| Cite | 277 Fed.Appx. 647 (8th Cir. 2008) |
| Level | Court of Appeals |
| Injunction Status | N/A |