Qualified Immunity to Iowa DOC Director for Recalculating Prisoners’ Release Dates
Qualified Immunity to Iowa DOC Director for Recalculating Prisoners’ Release Dates
by David M. Reutter
The Eighth Circuit Court of Appeals has upheld a district court’s grant of qualified immunity in a civil rights action brought by four ex-prisoners who were held beyond their release dates.
The prisoners, Richard Scott, Tim Burney, Kevin Underwood and J’Won Wilder, filed a lawsuit under 42 U.S.C. § 1983 against Iowa Department of Corrections (IDOC) director John R. Baldwin, seeking monetary and injunctive relief. They alleged that Baldwin had failed “to timely recalculate the end dates” of their sentences following the Iowa Supreme Court’s decision in Anderson v. State, 801 N.W.2d 1 (Iowa 2011). In that case, the Courtheld that Iowa law requires prisoners to receive credit for time served “for supervision of services.”
Within weeks of the Anderson ruling, Baldwin knew it would impact “approximately 3,444 offenders.” Working some overtime, the IDOC began recalculating each prisoner’s release date. The first affected prisoner was freed on August 26, 2011; through December 8, 2011, the IDOC released more than 200 prisoners. The plaintiffs served between 43 and 60 days beyond their release dates.
While it was undisputed that the plaintiffs were held beyond the end of their sentences, the issue was whether Baldwin “reasonably could have believed” the time spent recalculating prisoners’ release dates after the ruling in Anderson was “lawful in light of clearly established law on the totality of the circumstances.”
The Eighth Circuit noted that Baldwin knew which prisoners were affected by Anderson, but did not know when to release them without recalculating their sentences. The plaintiffs did not allege that Baldwin had been notified they were being over-detained, or that he detained them after he was aware of their new release dates.
Established law imposed a “duty to investigate” upon Baldwin, but there was no authority regarding the time he had to recalculate the plaintiffs’ sentences. “Under the circumstances,” the appellate court concluded, “the law did not fairly warn him that the amount of time spent recalculating thousands of release dates, including the plaintiffs’, recklessly disregarded their constitutional right to release.” As such, Baldwin was entitled to qualified immunity. See: Scott v. Baldwin, 720 F.3d 1034 (8th Cir. 2013).
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