AELE LAW LIBRARY OF CASE SUMMARIES:
Corrections Law for
Jails, Prisons and Detention Facilities
Administrative Liability
Prison superintendents
could not be held vicariously liable for alleged violations of inmate's
constitutional rights. No personal involvement was shown in any action
which allegedly resulted in the prisoner's placement in a restricted housing
unit without due process. Ford v. Wolfe, No. 05-2136, 156 Fed. Appx. 499
(3rd Cir. 2005). [N/R]
New York prisoner's
complaint adequately claimed personal involvement of the Commissioner of
the state's Department of Correctional Services in failing to act on information
that unconstitutional practices were occurring in the handling of appeals
prisoner disciplinary determinations to pursue federal civil rights claim
against him personally. The prisoner claimed that the department had a
policy or custom of upholding constitutionally defective disciplinary determinations,
and then reversing those affirmances if the prisoner filed a state court
lawsuit. He also contended that the Commissioner and his deputy created
this policy, and failed to provide adequate training and supervision for
employees of the Department who were in charge of disciplinary hearings.
James v. Aidala, No. 04-CV-62101, 389 F. Supp. 2d 451 (W.D.N.Y. 2005).
[N/R]
Prisoner failed to state a claim against
the Michigan Dept. of Corrections Director for interference with his right
of access to the courts or for the loss of his property, when he failed
to show that the director had any direct involvement in these alleged deprivations.
The defendant's "supervisory capacity does not make him liable for
the alleged deprivations by an unspecified prison official." Sarr
v. Martin, #02-1639, 53 Fed. Appx. 760 (6th Cir. 2002). [N/R]
Commissioner of Department of Corrections
could not be held liable for alleged assaults on prisoner by correctional
employees or for alleged retaliation against prisoner for complaining when
no personal involvement in the incidents was shown. Letters of complaint
that prisoner sent to his office were merely forwarded by staff members
to the appropriate investigators. Garvin v. Goord, 212 F. Supp. 22d 123
(W.D.N.Y. 2002). [N/R]
New York commission of correction
members can not be held liable for conditions; commission is a "watchdog"
without direct powers to control facilities. Brody v. McMahon, 684 F.Supp.
(N.D. N.Y. 1988).
Co. prisoners stated civil rights claim against
state officials for failure to authorize and approve funds needed to alleviate
unconstitutional overcrowding. Eleventh amendment no bar to claim. Libby
v. Marhsall, 653 F.Supp. 359 (D. Mass. 1986).
Failure to fulfill statutory duties not grounds
for Section 1983 liability. Balli v. Haynes, 804 F.2d 306 (5th Cir. 1986).
Law on administrative liability not fully
clear. Crisoptimo v. Nettleship, 800 F.2d 11 (1st Cir. 1986).
Parole board could be liable for negligent
supervision when working inmate raped woman. Reynolds v. Ohio, 471 N.E.2d
776 (Ohio 1984).
Prison officials can be personally liable
for inmate injury after noncompliance with court-ordered changes designed
to reduce prison violence. Williams v. Bennett, 689 F.2d 1370 (11th Cir.
1982); cert denied 52 LW 3336 (10/31/83).
Prisoner's fear of retaliation could be grounds
for tolling statute of limitations concerning his suit against warden.
Ross v. United States, 574 F.Supp. 536 (S.D. N.Y. 1983).
Prison officials liable to inmate for punitive
damages for remaining on disciplinary hearing board denying inmate impartial
hearing. Merritt v. De Los Santos, 721 2d 598 (7th Cir. 1983).
Prison officials liable for improper screening
of armed trustees which resulted in inmate being wounded. Jackson v. Hollowell,
714 F.2d 1372 (5th Cir. 1983).
Deprivation of liberty claim (confinement
past end of sentence) not basis for Section 1983 claim; state tort remedies
are adequate unless prison officials acted with deliberate indifference.
Haygood v. Younger, 718 F.2d 1472 (9th Cir. 1983).
Prison superintendent liable for due process
violations at disciplinary hearing. King v. Higgins, 702 F.2d 18 (1st Cir.
1983).
Warden not liable for unconstitutional disciplinary
hearing since he was not personally involved. Franklin v. Israel, 558 F.Supp.
712 (W.D. Wis. 1983).
Administrator not liable for negligence in
Section 1983 suit by inmate assaulted by other inmate. Risner v. Duckworth,
562 F.Supp. 378 (N.D. Ind. 1983).
No liability to corrections officials --
processing inmate's civil rights complaint. Johnson v. Hubbard, 698 F.2d
286 (6th Cir. 1983).
Arkansas state prison director could be liable
for segregation policies which created "inmate assault" situations.
Messimer v. Lockhart, 702 F.2d 729 (8th Cir. 1983).
Corrections officials not liable for improper
disciplinary hearings. Sommer v. Dixon, 709 F.2d 173 (2nd Cir. 1983).
Secretary of Corrections and Warden are not
"law enforcement" officials for purposes of state tort claim
act. Anchondo v. Correctional Dept., 666 P.2d 1255 (N.M. 1983).
Prison officials immune from liability for
alleged violations of inmate's due process in disciplinary hearing; $1
damages and $1,500 in attorney fees overruled. Segarra v. McDade, 706 F.2d
1301 (4th Cir. 1983).
Building administrator personally liable
for denying inmate access to court. Lamar v. Steele, 693 F.2d 559 (5th
Cir. 1982).
State director of corrections is not liable
for negligent acts occurring in county or local jails. Dillon v. Director,
Dept. of Corrections, 552 F.Supp. 30 (W.D. Va. 1982).
California court immunizes public entities
from wrongful death actions brought on behalf of prisoners. Lowman v. Los
Angeles Co., 179 Cal.Rptr. 709 (App. 1982).
California appeals court rules that plaintiff
who was under arrest but had not yet been incarcerated in a penal facility
was not a "prisoner" and that city did not have immunity from
liability. Griffith v. City of Monrovia, 184 Cal.Rptr. 709 (App. 1982).
Government officials performing discretionary
duties have qualified "good faith" immunity unless their conduct
violates clearly established statutory or constitutional rights of which
a reasonable person would have known. Harlow v. Fitzgerald, U.S. 102 S.Ct.
2727 (1982), clarifying the immunity standards or tests as set forth in
Gomez v. Toledo, 46 U.S. 635, 100 S.Ct. 1920 (1980); Procunier v. Navarette,
434 U.S. 555, 98 S.Ct. 855 (1978) and other Supreme Court cases which discuss
immunity of government officials, including state and local correctional
officials.
Court of appeals holds that superintendent's
failure to obey 1975 court order regarding conduct of disciplinary hearings
gives rise to contempt of court finding; affirms $5,000 fine. Powell v.
Ward, 643 F.2d 924 (2nd Cir. 1981).
Inmates lack standing to file Section 1983
claim to challenge actions of state executive and judicial officials who
blocked their attempt to secure criminal prosecution of guards. Leeke v.
Timmerman, 454 U.S. 83, 102 S.Ct. 69 (1981).
Pennsylvania District Court dismisses prisoner's
suit against Attorney General and Director of Bureau of Prisons for lack
of jurisdiction and venue; court also holds that defendants were entitled
to sovereign immunity. McKnight v. Civiletti, 497 F.Supp. 657 (E.D. Pa.
1980).
Federal torts claim act did not bar claimant
from direct suit against federal prison officials for death of son in prison
because of improper medical care. Carlson v. Green, 446 U.S. 1, 100 S.Ct.
1468 (1980).
Federal Court dismisses inmate's suit against
governor and county sheriff alleging deprivation of constitutional rights
due to conditions of confinement. Carwile v. Ray, 481 F.Supp. 33 (E.D.
Wash. 1979).
State prison officials entitled to immunity
when "rights" associated with inmate's mail were not established
at time incident occurred. Procunier v. Navarette, 434 U.S. 555, 98 S.Ct.
855 (1978).