LaChance v. Commissioner of Correction
463 Mass. 767
| Mass. | 2012Background
- LaChance, an inmate at SBCC, was held in SMU administrative segregation on awaiting action status from Jan–Nov 2006.
- During this period, he received only weekly informal status reviews under DOC SMU regulations.
- He was subjected to far more restrictive conditions in SMU than in the J-l unit.
- His confinement stemmed from disciplinary and transfer considerations, with ongoing efforts to transfer or reclassify him.
- Plaintiff sued for due process violations, statutory/regulatory protections, and damages; superior court granted partial relief to LaChance on due process grounds.
- The defense argued for qualified immunity and limited damages, while the court addressed whether due process protections required DSU-like procedures for awaiting action confinement.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether ten months in awaiting action status violated due process | LaChance had DSU-like protections; due process required hearings | No DSU-like protections required for awaiting action in SMU | Yes, ten months exceeded due process limits and required protections |
| Whether DSU procedures apply to SMUAwaiting action confinement | DSU protections should apply due to akin conditions | DSU regs not triggered in SMU by awaiting action | DSU-like protections apply; due process required |
| Whether defendants are entitled to qualified immunity | Right to DSU-like hearings was clearly established | Outer limit of reasonable confinement not clearly established in 2006 | Qualified immunity available; damages claims against individuals barred |
| Result of summary judgment on §1983 claims against individuals | Damages claims viable for individual defendants | Individual §1983 claims barred by qualified immunity | Remanded for entry of summary judgment in favor of defendants in their individual capacities |
Key Cases Cited
- Sandin v. Conner, 515 U.S. 472 (U.S. 1995) (inmate liberty interest defined by atypical and significant hardship)
- Wilkinson v. Austin, 545 U.S. 209 (U.S. 2005) (extreme isolation and DSU-like conditions trigger due process protections)
- Hoffer v. Commissioner of Correction, 412 Mass. 450 (Mass. 1992) (DSU procedural protections are constitutionally required)
- Haverty v. Commissioner of Correction, 437 Mass. 737 (Mass. 2002) (DSU regulations described as constitutionally required regulatory scheme)
- Royce v. Commissioner of Correction, 390 Mass. 425 (Mass. 1983) (rule of reason governs duration of administrative segregation)