Proctor v. LeClaire
715 F.3d 402
| 2d Cir. | 2013Background
- Proctor, a New York State prisoner, has been administratively confined in SHU since 2003 at Great Meadow or Clinton, with periodic reviews every 60 days.
- The 2003 hearing authorized administrative segregation; Proctor challenged that proceeding in Proctor I (2005–2008), which was dismissed on various grounds.
- Proctor II (2011) held that his periodic-reviews challenge was barred by claim preclusion and issue preclusion based on Proctor I matters, tying the 2010 Complaint to the prior litigation.
- Proctor filed the present 2010 amended Complaint against LeClaire, asserting due process violations in the periodic reviews and alleging new facts, falsity of reasons, and failure to expunge records.
- The district court granted LeClaire’s dismissal motion, treating the periodic-reviews claim as precluded and barred by prior determinations; Proctor appealed.
- The appellate court vacated the district court’s judgment and remanded, holding that the prior rulings did not fully preclude a separate due process claim arising from post-2003 periodic reviews.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether claim preclusion bars Proctor's periodic-reviews claim | Proctor asserts periodic reviews were new and not decided in Proctor I | LeClaire argues same-transaction bar applies | Partially reversed; preclusion not fully applicable to post-2003 reviews |
| Whether issue preclusion bars the periodic-reviews claim | Proctor contends issues were not actually decided or essential to Proctor I | Defendant argues prior merits decision precludes new issue | Partially reversed; issues not fully precluded ss to post-2003 reviews |
| Whether periodic reviews fall within the same transaction as initial confinement | Periodic reviews are distinct procedures with different factual predicates | Viewed as same transaction by Proctor II | Not same transaction; should be considered separately on remand |
| Whether LeClaire's personal involvement is adequately pled | Proctor alleges LeClaire's participation in 60-day reviews | LeClaire’s involvement insufficiently pled | Background issue; remand for proper consideration of personal involvement |
Key Cases Cited
- First Jersey Securities, Inc. v. Western Isotopes, 101 F.3d 1450 (2d Cir. 1996) (framework for res judicata and final judgments on the merits)
- Computer Associates International, Inc. v. Altai, Inc., 126 F.3d 365 (2d Cir. 1997) (scope of litigation determined by the complaint; post- filing conduct outside scope)
- Interoceania Corp. v. Sound Pilots, Inc., 107 F.3d 86 (2d Cir.) (continuing series of acts; res judicata limited to same cause of action)
- Nevada v. United States, 463 U.S. 110 (1983) (finality and identical-issue considerations for res judicata and collateral estoppel)
- First Jersey Securities, Inc. v. First Jersey Securities, Inc., 101 F.3d 1450 (2d Cir. 1996) (reiterating res judicata scope and final judgment aspects)
- Lawlor v. National Screen Service Corp., 349 U.S. 322 (1955) (causes of action; transactions continuity in res judicata)