Young v. Wall
2011 U.S. App. LEXIS 7692
| 1st Cir. | 2011Background
- RIDOC stopped paying interest on inmate accounts effective June 1, 2002 and later adopted a no-interest policy (May 6, 2003).
- Inmate wages are deposited into encumbered (25% up to $1,000) and available accounts; encumbered funds are released at release.
- Plaintiff Edward Young, Sr., incarcerated before and after the change, alleged that stopping interest violated his property rights and due process.
- Facilities policy (Policy No. 2.17) historically credited interest to inmates; RIDOC announced changes in August 2002 and formally codified them in 2003.
- District court dismissed the taking claim and granted summary judgment on due process; First Circuit reviews de novo, focusing on existence of a property right in interest not yet credited.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether there is a constitutionally protected property interest in unpaid interest | Young argues state law creates entitlement to accrued interest | RIDOC policy merely discretionary and not a guaranteed right | No property right in unpaid interest; not protected by constitution |
| Whether state common law creates such a property right | Common law follows principal with interest; creates entitlement | Common law does not create a right in interest for inmates | Common law does not create entitlement to interest in inmate accounts |
| Whether state statutory law creates a property right to interest | Statute implies entitlement to wages and related interest | Statute does not address interest and is silent on this point | Statute silent on interest; does not create protection for future interest |
| Whether policy/practice can create a constitutionally protected entitlement | Institutional policy generated a mutual understanding of ongoing interest | Policy was discretionary and could be changed prospectively | Policy change was prospective and did not deprive a protected property interest |
| Whether due process requires notice before changing the policy | Procedural due process required notice and hearing | No property interest, so due process not triggered | No notice/hearing required absent a property interest |
Key Cases Cited
- Phillips v. Washington Legal Found., 524 U.S. 156 (1998) (Constitution protects property interests; not created by the Constitution itself)
- Bd. of Regents of State Colls. v. Roth, 408 U.S. 564 (1972) (Interest depends on state-created entitlement bases)
- Reynolds v. Wagner, 128 F.3d 166 (3d Cir. 1997) (Property interest requires legitimate claim of entitlement from state law)
- Wilkinson v. Austin, 545 U.S. 209 (2005) (State policies/practices can create entitlement in certain contexts)
- Perry v. Sindermann, 408 U.S. 593 (1972) (Entitlement must be proved against institutional policies and practices)
- Wolff v. McDonnell, 418 U.S. 539 (1974) (Due process rights in prison contexts; limitations on rights during incarceration)
- Givens v. Alabama Dep't of Corr., 381 F.3d 1064 (11th Cir. 2004) (State law can create limited property rights; context-specific)