43. Transfers.
U.S. District Court LIBERTY INTEREST
Fermin-Rodriguez v. Westchester County Jail Med., 191 F.Supp.2d 358 (S.D.N.Y. 2002). An inmate brought a pro se [section] 1983 action against county jail and federal law enforcement officials. The district court dismissed the case, finding that the inmate had no liberty interest in being returned to a state prison from a county jail, and that the delay in returning the inmate to state detainee status was not a due process violation. The court noted that prison officials generally have discretion to transfer an inmate from one correctional facility to another. The inmate had claimed that conditions in the state...
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