Ikeim Chachar Claude Vaster v. Washington State Dept Of Corr, 76172-2

Background

Plaintiffs Ikeim Vaster, Albert James Reeves, and Tristan Beeman were transferred to community custody in lieu of early release and signed DOC paperwork about the Department's "swift and certain" violation process.
Each was accused of community custody violations, received full evidentiary hearings before DOC hearing officers, and had their early release revoked and were returned to total confinement to serve the remainder of their sentences.
Plaintiffs sued DOC and DOC officials alleging federal due process violations under 42 U.S.C. § 1983 and a state false imprisonment claim, arguing DOC lacked authority to return them to total confinement because RCW 9.94A.737 limits sanctions to 30 days.
DOC moved to dismiss under CR 12(b)(6); the trial court granted dismissal with prejudice, holding RCW 9.94A.633(2)(a) authorizes return to total confinement and DOC’s notice did not violate due process.
Plaintiffs appealed; the Court of Appeals reviewed statutory interpretation and procedural/substantive due process claims de novo and affirmed dismissal.

Issues

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether DOC may revoke community custody granted in lieu of earned early release and return an offender to total confinement for the remainder of the sentence	RCW 9.94A.737’s "swift and certain" scheme caps confinement sanctions (30 days or 3 days for low-level violations) and therefore precludes revocation to serve the remaining sentence	RCW 9.94A.633(2)(a) separately authorizes transfer to "a more restrictive confinement status," including return to total confinement for offenders placed in community custody in lieu of earned early release	Held: RCW 9.94A.633(2)(a) authorizes return to total confinement; interpreting otherwise would render that provision meaningless
Whether DOC’s failure to inform these offenders they could be returned to total confinement violated procedural due process	Plaintiffs: lack of specific notice that revocation to total confinement was possible deprived them of required process	DOC: Plaintiffs received written notice of alleged violations, full evidentiary hearings, and are presumed to know the law; no statutory notice requirement for RCW 9.94A.633 sanctions	Held: No procedural due process violation — plaintiffs received required hearing protections and are presumed to know the law
Whether DOC’s notice practice violated substantive due process as "shocking to the conscience"	Plaintiffs: misleading notice implying only RCW 9.94A.737 sanctions were possible was arbitrary and punitive	DOC: Conduct not arbitrary or egregious; practices do not rise to conscience-shocking standard	Held: No substantive due process violation — conduct not conscience-shocking
Whether § 1983 and false imprisonment claims survive absent a constitutional violation	Plaintiffs: asserted § 1983 and false imprisonment claims tied to due process violation	DOC: Without constitutional violation, § 1983 fails; false imprisonment derivative and barred (limitations as to at least one plaintiff)	Held: § 1983 claim fails; false imprisonment claim fails as derivative (and some claims time-barred)

Key Cases Cited

State v. Bruch, 182 Wn.2d 854 (discussing DOC authority to convert confinement into community custody in lieu of early release)
In re Pers. Restraint of Price, 157 Wn. App. 889 (legislative structured sanctions do not remove DOC power to revoke community custody and return offender to confinement)
Morrissey v. Brewer, 408 U.S. 471 (establishing minimum due process protections for parole revocation hearings)
County of Sacramento v. Lewis, 523 U.S. 833 (substantive due process requires conduct so arbitrary it is "shocking to the conscience")
Braam v. State, 150 Wn.2d 689 (negligence insufficient for substantive due process violation)
Sintra, Inc. v. City of Seattle, 119 Wn.2d 1 (when seeking money damages, substantive due process breach must be invidious or irrational)