Dustin Williamson v. Bryan Stirling
912 F.3d 154
4th Cir.2018Background
- In Nov. 2013, 17-year-old pretrial detainee Dustin Williamson was transferred from Barnwell County custody to South Carolina Department of Corrections (SCDC) as a "safekeeper" after he sent a threatening letter and struck an officer; Governor approved the transfer after SCDC Director Stirling recommended it.
- Williamson was housed in restrictive units (Kirkland MSU then Lee RHU) in near-solitary conditions (≈23–24 hours/day) with limited recreation, visitation, and law-library access; confinement continued about 3.5 years with renewals every ~90 days.
- The safekeeper process is governed by S.C. Executive Order 2000-11, which prohibits safekeeping for the mentally ill and requires documentation and periodic renewal showing good cause/no material change.
- Williamson alleges substantive and procedural Fourteenth Amendment due process violations under 42 U.S.C. § 1983: that the conditions were punitive (substantive) and that he received no notice/hearing before or during prolonged safekeeping (procedural).
- District court granted summary judgment to five defendants (including SCDC Director Stirling and Sheriff Carroll); the Fourth Circuit affirmed as to two (Charlton, Miller) for lack of personal involvement, vacated as to Stirling and Carroll and remanded for trial on disputed factual issues and qualified-immunity questions.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether prolonged safekeeper solitary confinement was "punishment" violating substantive due process | Williamson: 3.5 years in near-total isolation for a single incident was excessive and punitive, not reasonably related to security needs | Stirling/Carroll: confinement was nonpunitive, justified by security and threat-prevention | There is a genuine fact issue; summary judgment vacated as to Stirling and Carroll — jury must decide reasonableness/proportionality under Bell v. Wolfish |
| Whether Williamson was entitled to procedural due process (notice/hearing) before/after safekeeping or renewals | Williamson: he was denied required hearings/notice and periodic review; statutory/regulatory process (Executive Order) was not observed | Defendants: administrative segregation for safety requires lesser or no pre-deprivation process; qualified immunity applies | Triable issues exist about whether confinement was disciplinary or administrative; procedural claims survive and remand required to assess whether Wolff/Hewitt/Mathews standards were met |
| Whether defendants (Stirling, Carroll, Charlton, Miller) were personally liable under § 1983 | Williamson: all named officials participated in or greenlit transfer/renewals | Defendants: some lacked sufficient personal involvement; Governor was final decisionmaker | Charlton and Miller lacked personal involvement → summary judgment affirmed as to them; Stirling and Carroll were sufficiently involved → summary judgment vacated as to them |
| Whether defendants are entitled to qualified immunity | Williamson: rights were clearly established (pretrial detainees cannot be punished; procedural protections required) | Defendants: law was not sufficiently clear as to administrative segregation for pretrial detainees, so immunity applies | Qualified immunity denied as to substantive claim; procedural-immunity denied for actions after Incumaa (2015); limited period before Incumaa may present a narrower immunity question left for remand |
Key Cases Cited
- Bell v. Wolfish, 441 U.S. 520 (1979) (pretrial detainees may not be punished; tests for punitive character of conditions)
- Wolff v. McDonnell, 418 U.S. 539 (1974) (procedural protections for prison disciplinary proceedings: notice, hearing, written statement)
- Hewitt v. Helms, 459 U.S. 460 (1983) (minimum procedural protections and periodic review for administrative segregation)
- Sandin v. Conner, 515 U.S. 472 (1995) (liberty-interest framework for convicted prisoners; distinguished from pretrial detainees)
- Mathews v. Eldridge, 424 U.S. 319 (1976) (balancing test for required procedural protections)
- Incumaa v. Stirling, 791 F.3d 517 (4th Cir. 2015) (prisoner entitlement to process for prolonged solitary; informs later qualified-immunity analysis)
- Dilworth v. Adams, 841 F.3d 246 (4th Cir. 2016) (applies Bell to procedural-due-process claims for pretrial detainees)
- Wilkinson v. Austin, 545 U.S. 209 (2005) (convicted prisoners’ liberty interest in avoiding assignment to supermax facilities; factors relevant to extreme isolation)
- Robles v. Prince George’s County, 302 F.3d 262 (4th Cir. 2002) (applies Bell’s substantive-due-process test to abusive conduct in custody)
- Harlow v. Fitzgerald, 457 U.S. 800 (1982) (qualified-immunity standard for government officials)
- Pearson v. Callahan, 555 U.S. 223 (2009) (courts may choose order of prongs in qualified-immunity analysis)
- Ashcroft v. al-Kidd, 563 U.S. 731 (2011) (clearly established law requires fair warning to officers)