Hatfield v. Scott.

PositionPrisoner alleges criminal justice department not paying interest on his inmate trust fund - Brief Article

U.S. Appeals Court

INMATE FUNDS

PRISONER ACCOUNTS

Hatfield v. Scott, 306 F.3d 223 (5th Cir. 2002). A state prison inmate brought a [section] 1983 action against a state's criminal justice department, alleging that failure to pay interest on his inmate trust fund account violated the Takings Clause. The district court denied summary judgment for the state and the state appealed. The appeals court reversed and remanded. The appeals court held that when interest from prisoners' trust accounts is used to pay for the administration of the fund, providing benefit to prisoners, there is no "taking." The court found that the inmate had waived any property interest he may have had...

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