AELE LAW LIBRARY OF CASE SUMMARIES:
Corrections Law for Jails, Prisons and Detention Facilities
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could not be held vicariously liable for alleged violations of inmate's
constitutional rights. No personal involvement was shown in any action
which allegedly resulted in the prisoner's placement in a restricted housing
unit without due process. Ford v. Wolfe, No. 05-2136, 156 Fed. Appx. 499
(3rd Cir. 2005). [N/R]
New York prisoner's complaint adequately claimed personal involvement of the Commissioner of the state's Department of Correctional Services in failing to act on information that unconstitutional practices were occurring in the handling of appeals prisoner disciplinary determinations to pursue federal civil rights claim against him personally. The prisoner claimed that the department had a policy or custom of upholding constitutionally defective disciplinary determinations, and then reversing those affirmances if the prisoner filed a state court lawsuit. He also contended that the Commissioner and his deputy created this policy, and failed to provide adequate training and supervision for employees of the Department who were in charge of disciplinary hearings. James v. Aidala, No. 04-CV-62101, 389 F. Supp. 2d 451 (W.D.N.Y. 2005). [N/R]
Prisoner failed to state a claim against the Michigan Dept. of Corrections Director for interference with his right of access to the courts or for the loss of his property, when he failed to show that the director had any direct involvement in these alleged deprivations. The defendant's "supervisory capacity does not make him liable for the alleged deprivations by an unspecified prison official." Sarr v. Martin, #02-1639, 53 Fed. Appx. 760 (6th Cir. 2002). [N/R]
Commissioner of Department of Corrections could not be held liable for alleged assaults on prisoner by correctional employees or for alleged retaliation against prisoner for complaining when no personal involvement in the incidents was shown. Letters of complaint that prisoner sent to his office were merely forwarded by staff members to the appropriate investigators. Garvin v. Goord, 212 F. Supp. 22d 123 (W.D.N.Y. 2002). [N/R]
New York commission of correction members can not be held liable for conditions; commission is a "watchdog" without direct powers to control facilities. Brody v. McMahon, 684 F.Supp. (N.D. N.Y. 1988).
Co. prisoners stated civil rights claim against state officials for failure to authorize and approve funds needed to alleviate unconstitutional overcrowding. Eleventh amendment no bar to claim. Libby v. Marhsall, 653 F.Supp. 359 (D. Mass. 1986).
Failure to fulfill statutory duties not grounds for Section 1983 liability. Balli v. Haynes, 804 F.2d 306 (5th Cir. 1986).
Law on administrative liability not fully clear. Crisoptimo v. Nettleship, 800 F.2d 11 (1st Cir. 1986).
Parole board could be liable for negligent supervision when working inmate raped woman. Reynolds v. Ohio, 471 N.E.2d 776 (Ohio 1984).
Prison officials can be personally liable for inmate injury after noncompliance with court-ordered changes designed to reduce prison violence. Williams v. Bennett, 689 F.2d 1370 (11th Cir. 1982); cert denied 52 LW 3336 (10/31/83).
Prisoner's fear of retaliation could be grounds for tolling statute of limitations concerning his suit against warden. Ross v. United States, 574 F.Supp. 536 (S.D. N.Y. 1983).
Prison officials liable to inmate for punitive damages for remaining on disciplinary hearing board denying inmate impartial hearing. Merritt v. De Los Santos, 721 2d 598 (7th Cir. 1983).
Prison officials liable for improper screening of armed trustees which resulted in inmate being wounded. Jackson v. Hollowell, 714 F.2d 1372 (5th Cir. 1983).
Deprivation of liberty claim (confinement past end of sentence) not basis for Section 1983 claim; state tort remedies are adequate unless prison officials acted with deliberate indifference. Haygood v. Younger, 718 F.2d 1472 (9th Cir. 1983).
Prison superintendent liable for due process violations at disciplinary hearing. King v. Higgins, 702 F.2d 18 (1st Cir. 1983).
Warden not liable for unconstitutional disciplinary hearing since he was not personally involved. Franklin v. Israel, 558 F.Supp. 712 (W.D. Wis. 1983).
Administrator not liable for negligence in Section 1983 suit by inmate assaulted by other inmate. Risner v. Duckworth, 562 F.Supp. 378 (N.D. Ind. 1983).
No liability to corrections officials -- processing inmate's civil rights complaint. Johnson v. Hubbard, 698 F.2d 286 (6th Cir. 1983).
Arkansas state prison director could be liable for segregation policies which created "inmate assault" situations. Messimer v. Lockhart, 702 F.2d 729 (8th Cir. 1983).
Corrections officials not liable for improper disciplinary hearings. Sommer v. Dixon, 709 F.2d 173 (2nd Cir. 1983).
Secretary of Corrections and Warden are not "law enforcement" officials for purposes of state tort claim act. Anchondo v. Correctional Dept., 666 P.2d 1255 (N.M. 1983).
Prison officials immune from liability for alleged violations of inmate's due process in disciplinary hearing; $1 damages and $1,500 in attorney fees overruled. Segarra v. McDade, 706 F.2d 1301 (4th Cir. 1983).
Building administrator personally liable for denying inmate access to court. Lamar v. Steele, 693 F.2d 559 (5th Cir. 1982).
State director of corrections is not liable for negligent acts occurring in county or local jails. Dillon v. Director, Dept. of Corrections, 552 F.Supp. 30 (W.D. Va. 1982).
California court immunizes public entities from wrongful death actions brought on behalf of prisoners. Lowman v. Los Angeles Co., 179 Cal.Rptr. 709 (App. 1982).
California appeals court rules that plaintiff who was under arrest but had not yet been incarcerated in a penal facility was not a "prisoner" and that city did not have immunity from liability. Griffith v. City of Monrovia, 184 Cal.Rptr. 709 (App. 1982).
Government officials performing discretionary duties have qualified "good faith" immunity unless their conduct violates clearly established statutory or constitutional rights of which a reasonable person would have known. Harlow v. Fitzgerald, U.S. 102 S.Ct. 2727 (1982), clarifying the immunity standards or tests as set forth in Gomez v. Toledo, 46 U.S. 635, 100 S.Ct. 1920 (1980); Procunier v. Navarette, 434 U.S. 555, 98 S.Ct. 855 (1978) and other Supreme Court cases which discuss immunity of government officials, including state and local correctional officials.
Court of appeals holds that superintendent's failure to obey 1975 court order regarding conduct of disciplinary hearings gives rise to contempt of court finding; affirms $5,000 fine. Powell v. Ward, 643 F.2d 924 (2nd Cir. 1981).
Inmates lack standing to file Section 1983 claim to challenge actions of state executive and judicial officials who blocked their attempt to secure criminal prosecution of guards. Leeke v. Timmerman, 454 U.S. 83, 102 S.Ct. 69 (1981).
Pennsylvania District Court dismisses prisoner's suit against Attorney General and Director of Bureau of Prisons for lack of jurisdiction and venue; court also holds that defendants were entitled to sovereign immunity. McKnight v. Civiletti, 497 F.Supp. 657 (E.D. Pa. 1980).
Federal torts claim act did not bar claimant from direct suit against federal prison officials for death of son in prison because of improper medical care. Carlson v. Green, 446 U.S. 1, 100 S.Ct. 1468 (1980).
Federal Court dismisses inmate's suit against governor and county sheriff alleging deprivation of constitutional rights due to conditions of confinement. Carwile v. Ray, 481 F.Supp. 33 (E.D. Wash. 1979).
State prison officials entitled to immunity when "rights" associated with inmate's mail were not established at time incident occurred. Procunier v. Navarette, 434 U.S. 555, 98 S.Ct. 855 (1978).
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