Classification and separation.

• Position: Prisoner litigation - Brief Article

U.S. District Court

CELL ASSIGNMENT

Dobbin v. Artuz, 143 F.Supp.2d 292 (S.D.N.Y. 2001). A state inmate brought a [section] 1983 action against prison officials and medical staff, arising from a fall down stairs at the prison. The district court granted summary judgment in favor of the defendants, finding they were not deliberately indifferent to the medical needs of the inmate. The inmate bad requested to be moved to a cell on the ground floor on several occasions but he had failed to demonstrate any medical need for such a move. The court noted that the inmate regularly received sick calls and medication upon request, including consultations with outside specialists in connection with his back condition. (Green Haven Correctional Facility, New York)

U.S. District Court

SEX OFFENDER

DUE PROCESS

Jones v. Puckett, 160 F.Supp.2d 1016 (W.D.Wis. 2001). A prisoner brought a [section] 1983 action against two corrections officials for violation of his Fourteenth Amendment rights in labeling him as a sex offender without due process. The district court granted summary judgment in favor of the defendants. The court held that the prisoner did not have a liberty interest in not being identified as a sex offender in prison records, noting that evaluation of the needs of prisoners was a normal prison procedure and such evaluations were not made a matter of public knowledge in such a way that would constitute a stigma. The court also found that the defendants were entitled to qualified immunity because, at the time of the prisoner's evaluation, no law held that an inmate had a Fourteenth Amendment liberty interest in not being so classified. (Oshkosh Correctional Institution, Wisconsin)

U.S. District Court

CUSTODY LEVEL

DUE PROCESS

Lile v. Simmons, 143 F.Supp.2d 1267 (D.Kan. 2001). An inmate brought a [section] 1983 action, individually and on behalf of others who are similarly situated, against state corrections officials. The inmate alleged he was denied due process with respect to determining his custody classification. The court denied the inmate's motion to certify a class action and granted summary judgment in favor of the defendants. The court found that the inmate had no protected liberty interest in a correct risk level classification, and that even if he had such an interest, his due process rights were not violated by his current "medium" classification. The court noted that a liberty interest in a particular custody classification may arise...