Billy Dean Smith and Jacob Lee Anagick v. State of Alaska, Department of Corrections
447 P.3d 769
Alaska2019Background
- In Sept. 2011 Smith and Anagick (DOC inmates) worked in a Prison Industries laundry program; following a shakedown they were placed in administrative segregation based on alleged escape implements found at their workstations.
- Administrative-segregation classification committee recommended continued segregation pending investigation; superintendent approved; the placements led to termination from their laundry jobs.
- Related disciplinary findings (possession of escape implements) were later overturned on state appeal for procedural defects.
- The inmates sued DOC officers in federal court alleging due process violations for job loss; the federal court granted summary judgment for defendants, holding no federal liberty interest in avoiding administrative segregation and granting qualified immunity.
- The inmates filed a separate state-court suit alleging state-constitutional liberty interests in rehabilitative jobs (invoking Ferguson), due process violations, First/Sixth Amendment claims, spoliation, and breach of employment contracts; the superior court granted summary judgment for DOC and officers.
- On appeal the Alaska Supreme Court affirmed: it assumed (but did not decide) the jobs might be rehabilitative, held the administrative-segregation proceedings satisfied due process under Mathews, and rejected the inmates’ procedural/pleading challenges.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether inmates had a state-created liberty interest in their laundry jobs (rehabilitative-program protection) | Jobs were rehabilitative under Ferguson and conferred a protected liberty interest requiring separate job-termination hearings | Jobs either were not rehabilitative or, even if they were, removal as a consequence of administrative segregation is permitted and existing procedures suffice | Court assumed arguendo the jobs could be rehabilitative but held administrative-segregation classification hearings satisfied any due process owed, so no violation |
| Whether administrative-segregation proceedings violated due process (Mathews balancing) | Administrative hearings relied on anonymous hearsay and lacked protections required for job termination | DOC contended hearings complied with regs/policy (timely classification hearing, superintendent review); additional hearings would add little value and burden DOC | Applying Mathews, the procedures (prompt classification hearing, written findings, superintendent review) met due process; additional termination hearings were unnecessary |
| Qualified immunity for DOC officers | Officers violated clearly established state or federal rights by causing loss of rehabilitative jobs | Any liberty interest was not clearly established in the circumstances; officers therefore entitled to qualified immunity | Court did not reach qualified immunity in depth because it found no constitutional violation; federal court previously held qualified immunity applied, and superior court’s grant of summary judgment was affirmed |
| Procedural/pleading requests (amend complaint; consolidate; spoliation relief) | Pro se plaintiffs sought leave to amend to add negligent-training, breach-of-contract, and spoliation claims and requested consolidation with a related suit | DOC argued new claims were legally insufficient or moot; consolidation was discretionary and premature | Court did not abuse discretion: negligent-training and contract claims would be futile or duplicated by existing procedures; spoliation remedy (presumption instruction) was granted earlier but moot on summary judgment; denial of consolidation was not manifestly unreasonable |
Key Cases Cited
- Ferguson v. State, Dep’t of Corr., 816 P.2d 134 (Alaska 1991) (prisoners have state-constitutional interest in continued participation in rehabilitative programs)
- Mathews v. Eldridge, 424 U.S. 319 (U.S. 1976) (three-factor test for required procedural due process protections)
- Wilkinson v. Austin, 545 U.S. 209 (U.S. 2005) (no federal liberty interest in avoiding transfer to more adverse prison conditions absent atypical and significant hardship)
- Sandin v. Conner, 515 U.S. 472 (U.S. 1995) (state-created liberty interests protected by Due Process Clause are limited to restraints imposing atypical and significant hardship)
- Thorne v. Dep’t of Pub. Safety, 774 P.2d 1326 (Alaska 1989) (sanction for failure to preserve video evidence is presumption that video would have favored plaintiff)
- Pearson v. Callahan, 555 U.S. 223 (U.S. 2009) (qualified immunity framework and elimination of mandatory Saucier sequence)
- James v. State, Dep’t of Corr., 260 P.3d 1046 (Alaska 2011) (state constitutional due process right to confront witnesses at disciplinary hearings imposing punitive segregation)