U.S. Appeals Court: VOCATIONAL DRUG.

• Position: Brief Article

Zimmerman v. Tribble, 226 F.3d 568 (7th Cir. 2000). An inmate brought a pro se civil rights action against state prison officials complaining about prison conditions. The district court dismissed the complaint under the Prison Litigation Reform Act (PLRA) and the inmate appealed. The appeals court affirmed in part and reversed and remanded in part. The appeals court held that the inmate did not state a claim for violation of due process in his transfer to a prison that did not offer programs enabling him to earn good time credits. The inmate had been transferred from a prison that had vocational training and substance abuse programs to a prison which did not have such programs. The inmate had alleged that had he completed the programs at the first prison he would have earned good time credits under state law, but the court noted that it was not inevitable that the...