Rex Chappell v. R. Mandeville, 2013 U.S. App. LEXIS 2192

Chappell, a California prisoner, was placed on contraband watch after drugs were found and suspected in his vicinity in April 2002.
Contraband watch involved continuous, highly restrictive confinement with wiring, clothing, restraints, bright lights, and surveillance to detect contraband passage.
Chappell claimed multiple conditions (constant bright lighting, no mattress, restraints, heat, and sensory deprivation) caused harm and argued due process rights were violated due to lack of notice/hearing before watch.
District court denied summary judgment on Eighth Amendment and due process claims against Mandeville and Rosario; the appeals court reviews qualified immunity de novo.
Court held Mandeville and Rosario are entitled to qualified immunity because law in April–May 2002 did not clearly establish unconstitutional conduct, reversing the district court’s partial denial.
Concurrence and dissent note factual disputes and argue that the Eighth Amendment claim regarding continuous bright light and other conditions could be actionable; the majority limits its holding to qualified immunity and does not decide on the merits.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Eighth Amendment: exposure to contraband watch conditions	Chappell argues conditions violated Eighth Amendment.	Mandeville/ Rosario contend not clearly established as unconstitutional; qualified immunity applies.	Qualified immunity; not clearly established at the time.
Continuous lighting and sleep deprivation	Continuous bright light violated Eighth Amendment as sleep deprivation.	No clearly established rule; penological purpose may justify lighting under some circumstances.	Not clearly established; qualified immunity applies on this ground.
Mattress deprivation	Mattress deprivation contributed to Eighth Amendment violation.	Law not clearly established; balanced by penological purpose and duration.	Not clearly established; qualified immunity applies.
Combination of conditions	Combined conditions produced an unconstitutional deprivation of basic needs.	No single deprivation shown; no clearly established rule on combined effects.	Not clearly established; qualified immunity applies.
Due Process: state-created liberty interest	State-created liberty interest existed via regulation; required due process protections.	No such interest or not clearly established; Sandin framework applies; qualified immunity.	Qualified immunity; no clearly established state-created liberty interest as of 2002.

Harlow v. Fitzgerald, 457 U.S. 800 (1982) (officials entitled to qualified immunity unless clearly established rights)
Pearson v. Callahan, 555 U.S. 223 (2009) (clarified sequencing for qualified immunity analysis)
Saucier v. Katz, 533 U.S. 194 (2001) (two-step approach to qualified immunity (mod. later by Pearson))
Hope v. Pelzer, 536 U.S. 730 (2002) (fair warning standard for clearly established law)
Keenan v. Hall, 83 F.3d 1083 (9th Cir. 1996) (continuous lighting; legitimate penological justification matters)
Hewitt v. Helms, 459 U.S. 460 (1983) (liberty interests created by regulations; Hewitt framework)
Wilson v. Seiter, 501 U.S. 294 (1991) (mutually reinforcing conditions and basic needs relevance)
Sandin v. Conner, 515 U.S. 472 (1995) (atypical and significant hardship as test for state-created liberty interests)
Mendoza v. Blodgett, 960 F.2d 1425 (9th Cir. 1992) (state-created liberty interest and due process analysis pre-Sandin context)
Wilkinson v. Austin, 545 U.S. 209 (2005) (Sandin-based approach to protected liberty interests in prison)
Meachum v. Fano, 427 U.S. 215 (1976) (due process rights limited to extreme changes in confinement)
Ramirez v. Galaza, 334 F.3d 850 (9th Cir. 2003) (fact-specific, context-dependent analysis for atypical hardship)