Nathaniel Brown v. Michael Randle
2017 U.S. App. LEXIS 2155
| 7th Cir. | 2017Background
- Nathaniel Brown was sentenced in Illinois for sex offenses in 1994; his prison term ended July 10, 2009, after which he was to serve three years of mandatory supervised release.
- Illinois did not release Brown on that date, issuing a Parole Violation Report alleging anticipatory violations: refusal to accept electronic GPS monitoring and lack of an approved lawful residence for sex offenders.
- The Illinois Prisoner Review Board later found (October 2009) that Brown had not violated release conditions, but the Department of Corrections reissued a violation report citing 20 Ill. Admin. Code §1610.110(a) and retained Brown until January 11, 2011 (18 months), when he was unconditionally released.
- Brown sued under 42 U.S.C. §1983 seeking damages for unlawful post-sentence detention, arguing Fourth Amendment (unreasonable seizure) and Fourteenth Amendment Due Process violations; he also alleged Eighth Amendment deliberate indifference to serious medical needs against the warden, Nedra Chandler.
- The court considered whether federal law clearly establishes a right to immediate release for sex offenders lacking approved residences (qualified-immunity question) and whether Brown stated facts showing Chandler’s personal culpability or harm from alleged medical mistreatment.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Fourth Amendment: right to immediate release when sentence ends despite supervised-release conditions | Brown: detention after sentence end was an unreasonable seizure; he should have been released even if later revoked | Defendants: no clearly established law requires immediate release of sex offenders who lack approved residences; qualified immunity applies | Court: No clearly established Fourth Amendment right here; defendants entitled to qualified immunity |
| Fourteenth Amendment Due Process: right to hearing before retention after sentence end | Brown: denied procedural due process (no pre-release hearing) | Defendants: Jago permits rescinding parole without hearing if action occurs before inmate reaches outside; no Due Process violation | Court: Jago controls; pre-release hearing not constitutionally required in this context |
| Effect of Prisoner Review Board decision favoring release | Brown: Board’s finding that he hadn’t violated release conditions should have compelled release | Defendants: Board determinations don’t bind DOC officials under state law; §1983 remedies are for federal, not state law, violations | Court: Board’s statement didn’t expressly establish lawful residence/consent to monitoring; federal law doesn’t require deference to state administrative rulings here |
| Eighth Amendment deliberate indifference re: medical care | Brown: Chandler withheld necessary care and placed him in general population causing risk | Defendants: Chandler had no personal role in treatment decisions; Brown alleges no actual harm from the six-week placement | Court: Dismiss claimant against Chandler — no personal involvement in care delays; no alleged or proven harm from six-week housing in general population; Eighth Amendment claim fails |
Key Cases Cited
- Belleau v. Wall, 811 F.3d 929 (7th Cir. 2016) (upholding GPS ankle bracelet as condition of release)
- Werner v. Wall, 836 F.3d 751 (7th Cir. 2016) (qualified immunity where law not clearly established that sex offenders must be released absent approved residence)
- Weems v. Little Rock Police Dep’t, 453 F.3d 1010 (8th Cir. 2006) (upholding residential-location limits for sex offenders)
- Doe v. Miller, 405 F.3d 700 (8th Cir. 2005) (upholding residency restrictions for sex offenders)
- Doe v. Lafayette, 377 F.3d 757 (7th Cir. 2004) (states may restrict sex offenders’ access to places where children congregate)
- Morrissey v. Brewer, 408 U.S. 471 (1972) (parolees entitled to notice and hearing before revocation once released)
- Jago v. Van Curen, 454 U.S. 14 (1981) (state may rescind parole without hearing if action occurs before prisoner reaches outside prison)
- Ashcroft v. al‑Kidd, 563 U.S. 731 (2011) (qualified‑immunity law cannot be defined at high level of generality)
- Anderson v. Creighton, 483 U.S. 635 (1987) (clearly established law must be particularized to the facts)
- Petties v. Carter, 836 F.3d 722 (7th Cir. 2016) (standards for Eighth Amendment medical-care claims)
- Iqbal v. Ashcroft, 556 U.S. 662 (2009) (no supervisory liability absent personal involvement)
- Vance v. Rumsfeld, 701 F.3d 193 (7th Cir. 2012) (en banc) (limits on vicarious liability for supervisors)
- Castle Rock v. Gonzales, 545 U.S. 748 (2005) (federal remedies do not enforce state law entitlements)
- Farmer v. Brennan, 511 U.S. 825 (1994) (deliberate indifference standard under Eighth Amendment)