Administrative segregation.

• Position: Little v. Terhune - Rahman X v. Morgan - Brief Article

3. Administrative Segregation U.S. District Court Little v. Terhune, 200 F.Supp.2d 445 (D.N.J. 2002). A prisoner housed in a maximum security PROGRAMS prison brought a civil rights suit against state prison officials for allegedly violating his EQUAL PROTECTION equal protection rights by failing to provide him with educational programming while he was confined in an administrative segregation unit. The district court held that the denial of educational programming to prisoners in administrative segregation did not violate equal protection on the basis that the programs were available to the general prison population, to younger inmates in administrative segregation, or to all inmates in segregation units at other institutions. The court noted that although inmates do not have a constitutional right to educational and work programs, once the state grants such rights to prisoners it may not invidiously discriminate against a class of inmates in connection with those programs unless the difference in treatment is rationally related to the legitimate governmental interest to justify the disparate treatment. The court found a legitimate connection, where prison officials' allocation priorities for the scarce resource of educational services responded to security concerns and budget restraints. The court also found that there was a legitimate government interest in promoting innovative prison programs that might be stymied by a requirement that there be system-wide...