Case: Edwards v. Johnson

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).  

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