U.S. Appeals Court: DUE PROCESS PUNISHMENT.

Sims v. Artuz, 230 F.3d 14 (2nd Cir. 2000). A former inmate brought a [sections] 1983 action against state prison officials alleging that they used, or condoned the use of, excessive force against him in connection with disciplinary proceedings that resulted in special confinement. The district court dismissed the case and the former inmate appealed. The appeals court vacated in part and remanded. The appeals court found that the former inmate's allegations stated Eighth Amendment claims for use of excessive force and that the deprivations suffered were sufficiently atypical to implicate a liberty interest in avoiding such punishment. The former inmate alleged that on three occasions he was subjected to beatings from corrections...