Case: Edwards v. Johnson

1:87-cv-00454 | U.S. District Court for the Southern District of Alabama

Filed Date: May 18, 1987

Closed Date: June 12, 1990

Clearinghouse coding complete

Case Summary

In 1987, an inmate brought suit seeking damages under 42 U.S.C. § 1983 for violations of his Eighth and Fourteenth Amendment rights by six administrators of the Holman Prison Unit where he was incarcerated. Plaintiffs also sought sanctions against defendants for violating the decree in another case, Pugh v. Locke, F.Supp. 308 (M.D. Ala.1976), PC-AL-010. The United States District Court for the Southern Division of Alabama (Magistrate Judge William Cassady) found against the plaintiff and gran…

In 1987, an inmate brought suit seeking damages under 42 U.S.C. § 1983 for violations of his Eighth and Fourteenth Amendment rights by six administrators of the Holman Prison Unit where he was incarcerated. Plaintiffs also sought sanctions against defendants for violating the decree in another case, Pugh v. Locke, F.Supp. 308 (M.D. Ala.1976), PC-AL-010. The United States District Court for the Southern Division of Alabama (Magistrate Judge William Cassady) found against the plaintiff and granted defendants summary judgment. Edwards v. Johnson, No. 87-0454, 1990 U.S. Dist. LEXIS 7993 (May 22, 1990).

Plaintiff had been involved in an attempted prison escape in 1986. Based on information from inmate sources, the plaintiff was selected for investigation and placed in administrative segregation in accordance with the prison's regulations for the duration of the investigation. Plaintiff argued a violation of his Eighth Amendment rights because the decision to confine him based upon such information contravened the injunction entered in Pugh v. Locke, which plaintiff contended prohibited reliance on inmate-informants for disciplinary purposes. In denying such a violation, the Court noted that the Pugh v. Locke injunction expired in 1984 and was replaced with a committee established to monitor prisons conditions. In addition, the Court found plaintiff's Eighth Amendment violation argument to be insubstantial.

Plaintiff also argued that his substantive due process rights under the Fourteenth Amendment were violated by the administration's failure to give him a status hearing within the 72-hour window prescribed by the regulations. Additionally, he argued that his procedural due process rights were violated because defendants' reliance on information that led to the decision to place him in administrative segregation was "arbitrary and capricious." In determining what process the plaintiff was due under the Due Process Clause of the Fourteenth Amendment, the Court found the prison had a heightened security interest in light of the attempted prison break. Due to the prison's security interest, the Court concluded that the periodic review of plaintiff's status, while not neatly within the 72-hour window, nonetheless comported with the requirements of due process.

The decision was subsequently affirmed by the United States District Court for the Southern District of Alabama, Southern Division, District Court (Judge William Brevard Hand). Edwards v. Johnson, No. 87-0454-BH-C, 1990 U.S. Dist. LEXIS 7980 (June 12, 1990).  

Information about the case is not available on PACER.

Summary Authors

Rebecca Bloch (2/15/2006)

People


Judge(s)

Cassady, William E. (Alabama)

Hand, William Brevard (Alabama)

Expert/Monitor/Master

Chandler, William B. III (Delaware)

Judge(s)

Cassady, William E. (Alabama)

Hand, William Brevard (Alabama)

Expert/Monitor/Master

Chandler, William B. III (Delaware)

Documents in the Clearinghouse

Document

Docket (PACER)

June 12, 1990 Docket

Magistrate's Opinion

1990 U.S.Dist.LEXIS 7993

May 22, 1990 Order/Opinion

Order

1990 U.S.Dist.LEXIS 7980

June 12, 1990 Order/Opinion

Docket

Last updated May 12, 2022, 8 p.m.

Docket sheet not available via the Clearinghouse.

State / Territory: Alabama

Case Type(s):

Prison Conditions

Key Dates

Filing Date: May 18, 1987

Closing Date: June 12, 1990

Case Ongoing: No

Plaintiffs

Plaintiff Description:

Prisoner incarcerated at Holman Prison Unit, Atmore, Alabama, serving a sentence of life without parole alleging a violation of his constitutional rights for placing him in administrative segregation

Plaintiff Type(s):

Private Plaintiff

Public Interest Lawyer: No

Filed Pro Se: Unknown

Class Action Sought: No

Class Action Outcome: Not sought

Defendants

Atmore State Prison, State

Case Details

Causes of Action:

42 U.S.C. § 1983

Constitutional Clause(s):

Cruel and Unusual Punishment

Due Process

Availably Documents:

Trial Court Docket

Any published opinion

Outcome

Prevailing Party: Defendant

Nature of Relief:

None

Source of Relief:

None

Issues

General:

Administrative segregation

Type of Facility:

Government-run