$5,000 Settlement for Missouri Prisoner’s Retaliation Claim After Eighth Circuit Dismissed Due Process Claim Over Falsified Disciplinary Report
by Chuck Sharman
It took over 15 months, but PLN finally received documentation that the Missouri Department of Corrections (DOC) paid $5,000 to state prisoner James Spann to settle claims that he was retaliated against by Jefferson City Correctional Center guards for filing grievances.
As PLN reported, Spann initially convinced the U.S. District Court for the Western District of Missouri that he was also denied due process when guards falsely accused him of raping a fellow prisoner and threw him into solitary confinement as punishment. But the U.S. Court of Appeals for the Eighth Circuit reversed that decision, restoring qualified immunity to the errant guards with a maddening bit of circular reasoning that found their own phony reports provided “some evidence” that Spann was guilty of the bogus charges. The decision serves as a warning to prisoners not to challenge prison disciplinary procedures on due process grounds; as the Eighth Circuit told Spann, there is no “clearly established due process right to a pristine” disciplinary proceeding, so the results can get messy. [See: PLN, Mar. 2024, p.19.]
Of interest to other prisoners, the Eighth Circuit said that when a prison disciplinary hearing results in sanctions not affecting the duration of a prisoner’s confinement—e.g., by loss of good-time credits—it is not subject to the due-process requirements laid out in Wolff v. McDonnell, 418 U.S. 539 (1974). Instead, the due-process analysis is conducted according to Mathews v. Eldridge, 424 U.S. 319 (1976), the Court said, because “a transfer to administrative segregation requires only informal, nonadversary due process procedures,” which Spann was provided.
Fortunately for Spann, the Eighth Circuit did not disturb the portion of the district court’s order that refused to dismiss his claims that “Defendants retaliated against him because he filed grievances … by denying him showers, denying outside recreation, opening his certified mail, denying him medical treatment, conducting excessive cell searches, and falsifying violation reports,” as the district court recalled. See: Spann v. Lombardi, 2021 U.S. Dist. LEXIS 214160 (W.D. Mo. Sep. 30, 2021).
It was those less incendiary allegations that the DOC agreed to settle, and Spann dismissed his suit in November 2023. He was represented in the settlement by attorneys Bradford B. Lear and Todd C. Werts of Lear Werts LLP in Columbia. See: Spann v. City of Jefferson City, USDC (W.D. Mo.), Case No. 2:14-cv-04259. Spann’s current status is unclear; the DOC’s website returned no results from a search for his name.
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Related legal case
Spann v. City of Jefferson City
| Year | 2021 |
|---|---|
| Cite | USDC (W.D. Mo.), Case No. 2:14-cv-04259 |
| Level | District Court |