Maurice Hardaway v. Brett Meyerhoff
734 F.3d 740
7th Cir.2013Background
- Hardaway, a Menard Correctional Center inmate, faced 2009 disciplinary charges for damage/misuse of property, forgery, and trafficking of official electronics contracts; the charge was expunged later, but he served six months in segregation.
- A disciplinary hearing found him guilty; he alleges he was denied the opportunity to present defenses and to view forged contracts used as evidence.
- He was housed in a six-gallery cell with a solid metal door, and requested relocation to a cell with metal bars due to a personal trauma, which was denied.
- After filing grievances, the ARB remanded to add more details to the report; Meyerhoff failed to revise, and the ARB ultimately affirmed removal of the charge, expunging it from his record.
- Hardaway filed suit in district court alleging a 182-day segregation violated due process under the Fourteenth Amendment; district court granted summary judgment on qualified immunity for Meyerhoff and Parnell.
- He appeals, arguing his confinement amounted to a liberty interest violation and defendants violated due process; the Seventh Circuit affirms the grant of qualified immunity.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether six months in segregation with stated conditions implicated a liberty interest | Hardaway—liberty interest implicated by atypical hardship | Meyerhoff/Parnell—no clearly established right at the time | No clearly established right; qualified immunity applies |
| Whether the conditions amounted to atypical and significant hardship | Conditions were severe enough to trigger due process | Conditions did not rise to atypical/significant hardship | Not met; not clearly established for these facts |
| Whether the district court correctly applied qualified immunity for the defendants | Ambiguity in Seventh Circuit baseline; error in ignoring potential rights | Lack of clearly established right; reasonable officials acted without notice | Affirmed district court; qualified immunity valid |
Key Cases Cited
- Marion v. Columbia Corr. Inst., 559 F.3d 693 (7th Cir. 2009) (liberty interest in segregation depends on atypical and significant hardship when combined with duration)
- Wilkinson v. Austin, 545 U.S. 209 (S. Ct. 2005) (conditions and duration of confinement determine due process rights)
- Sandin v. Connor, 515 U.S. 472 (S. Ct. 1995) (duration and conditions determine deprivation of liberty interest)
- Thomas v. Ramos, 130 F.3d 754 (7th Cir. 1997) (six months vs. physical health considerations; not necessarily atypical hardship)
- Pearson v. Callahan, 555 U.S. 223 (S. Ct. 2009) (two-step qualified immunity analysis; right-established inquiry may proceed first or second)
- Harlow v. Fitzgerald, 457 U.S. 800 (S. Ct. 1982) (personal immunity from liability when conduct violates not clearly established)