Immunity.

• Position: Brief Article

U.S. District Court

FEDERAL TORT CLAIMS ACT

ABSOLUTE IMMUNITY

Brown v. McElroy. 160 F.Supp.2d 699 (S.D.N.Y. 2001). A prisoner brought an action against the Immigration and Naturalization Service (INS) and Public Health Service (PHS) alleging inadequate medical treatment and other complaints. The district court found that PHS officials were absolutely immune from liability on the claim of inadequate health care. The court found no constitutional violation from the alleged conditions of a cold room, no clean bed linens, toiletries, or clean clothing. (Buffalo Federal Detention Facility, Batavia, New York)

U.S. District Court

QUALIFIED IMMUNITY

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...