Alaska State Supreme Court Rules Due Process Afforded to Prisoners Seeking Laundry Job Reinstatement
by Chad Marks
Billy Dean Smith and Jacob Lee Anagick were prisoners at the Lemon Creek Correctional Center in Alaska when an unannounced shakedown took place. The reason for the search: Prison staff had information that there was a planned escape.
Both men worked at the Prison Industries Program, providing laundry services to the Alaska Marine Highway System. According to incident reports, guards found escape paraphernalia at their work stations. Both consistently denied any intent or plan to escape.
Despite their claims of innocence, both men were carted off to the SHU and placed on administrative detention. According to policy, they were provided a hearing within six days. The warden signed off on a recommendation that both men remain in segregation pending an investigation.
Eventually both prisoners were found to have possessed escape implements. They appealed the finding to the superior court, which found that their procedural rights were violated.
In April 2015, the men filed suit in state superior court naming the Department of Corrections’ commissioner and unknown Department of Corrections (DOC) employees as defendants.
They alleged that under the Alaska Constitution they had a liberty interest in their laundry jobs. In addition, they asserted that their laundry jobs were rehabilitative and that pursuant to Ferguson v. State Department of Corrections they were entitled to due process before they could be terminated, and that they were denied that due process.
The court granted summary judgment to the DOC and its guards. Smith and Anagick appealed, arguing that they had a clearly established liberty interest in their jobs, and that the superior court erred procedurally.
On appeal, the Alaska Supreme Court looked at Ferguson, acknowledging that the Alaska Constitution makes clear that prisoners have a right to rehabilitation. However, the Court did not reach the question of whether the prisoners had a protected liberty interest in their jobs because the Court concluded that they received due process.
In reaching the prisoner due process claim, the court looked to the U.S. Supreme Court decision in Mathews v. Eldridge, 424 U.S. 319 (1976), which outlines three factors courts to consider, (1) the private interest that will be affected by the official action, (2) the risk of an erroneous deprivation of such interest through the procedures used and the probable value, if any, of additional or substitute procedural safeguards, and (3) the [State]’s interest, including the function involved and the fiscal and administrative burdens that the additional or substitute procedural requirement would entail.
Smith and Anagick asserted a private interest in their continued participation in the jobs that they characterized as rehabilitative. The Court found that, even assuming that their jobs were rehabilitative and thus subject to constitutional due process protections, the proceedings for their placement in administrative segregation satisfied any due process requirements that they may have had.
Thus, the Court concluded that both prisoners received adequate due process prior to their termination from the laundry. Accordingly, the Court affirmed the superior court’s award of summary judgment to the DOC. See: Smith et al. v. State of Alaska, Department of Corrections, et al., ___________(8-30-19).
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Related legal case
Smith et al. v. State of Alaska, Department of Corrections, et al.