Salyer v. Neal, 3:23-cv-01004

Levi Salyer, an Indiana prisoner, filed a pro se complaint alleging that prison officials at Westville Correctional Facility held him in disciplinary segregation for over thirty days past his scheduled reclassification date.
Salyer claims that due to staff negligence and administrative delays, he remained in harsh segregation conditions despite being eligible for transfer to general population.
The complaint describes more restrictive conditions in segregation, such as reduced recreation time, limited social contact, restricted visitation, limitations on legal materials, and other constraints.
Salyer sues specific prison officials, alleging violations of his Eighth and Fourteenth Amendment rights, seeking damages and reclassification.
The court screened the complaint under 28 U.S.C. § 1915A to determine if it stated a plausible constitutional claim or if it should be dismissed at the pleading stage.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Due Process violation for extended segregation	Officials unlawfully kept Salyer in disciplinary segregation past the lawful date, without due process	No protected liberty interest in prison classification or brief extensions in segregation	Dismissed—no plausible due process claim; thirty days not sufficient for concern
Eighth Amendment violation—harsh conditions	Conditions in segregation denied basic human needs and caused emotional harm	No deliberate indifference; conditions not severe enough to violate Eighth Amendment	Dismissed—conditions did not reach required threshold, and no specific harm alleged
Liability of named defendants	Defendants knew of and facilitated unlawful segregation	Defendants not personally involved or aware in a manner that would establish liability	Dismissed—no specific facts showing personal liability
Leave to amend	Salyer should be able to correct or clarify his claims	Defective pleadings can be amended unless futile	Leave granted to amend by May 8, 2025

Bell Atlantic Corp. v. Twombly, 550 U.S. 544 (Pleading standards for plausibility)
Ashcroft v. Iqbal, 556 U.S. 662 (Facial plausibility requirement for complaints)
Sandin v. Conner, 515 U.S. 472 (Liberty interests—atypical and significant hardship in prison segregation)
Wilkinson v. Austin, 545 U.S. 209 (Duration and conditions relevant to liberty interests in prison segregation)
Farmer v. Brennan, 511 U.S. 825 (Standard for Eighth Amendment deliberate indifference)
Marion v. Columbia Correction Inst., 559 F.3d 693 (Segregation of 2–90 days generally does not trigger due process concerns)
DeTomaso v. McGinnis, 970 F.2d 211 (No liberty or property in prison classification)