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Law School Case Brief

Walker v. Bates - 23 F.3d 652 (2d Cir. 1994)


When restrictive confinement within a prison is expressly imposed as a disciplinary sanction, there will ordinarily be no doubt that the confinement impaired a liberty interest protected by state law and that the due process procedures are therefore required. An inmate who is or may be sentenced to a term of confinement in a special housing unit has a right to the procedural protections of the due process clause, including the right to call witnesses in his defense.


On December 5, 1990, during the course of his confinement at a prison maintained by the New York State Department of Correctional Services, Plaintiff-appellant Robert Walker was issued an "Inmate Misbehavior Report" by Corrections Officer P. Youmans. In the Misbehavior Report, Walker was charged with violation of an institutional rule prohibiting the possession of contraband in the form of a weapon and violation of another institutional rule prohibiting the possession of state bedding in excess of authorized issue. At the disciplinary hearing, defendant-appellee L. Bates refused Walker’s request to call witnesses, found him guilty of the violations, and imposed a sentence of confinement. The administrative appeals board reversed the ruling and authorized a rehearing within seven days. No rehearing was held, and Walker was not released until 14 days later.  Thereafter, Walker brought an action against defendant Bates. In the said complaint, grounded in the provisions of 42 U.S.C.S. § 1983, Walker alleged that his constitutional procedural due process rights were violated in the course of a disciplinary hearing that resulted in a decision to confine him to the Special Housing Unit ("SHU") at the Facility. The district court concluded that reversal of the disciplinary hearing decision on administrative appeal cured any procedural defects in the hearing and dismissed the complaint pursuant to the provisions of Fed. R. Civ. P. 12(b)(6) for failure to state a claim upon which relief may be granted. Walker challenged the district court’s judgment.


Did the reversal of the disciplinary hearing decision on administrative appeal cure any procedural defects in the hearing, thereby justifying the dismissal of inmate Walker’s complaint?




The United States Court of Appeals for the Second Circuit reversed the judgment. The Court held that plaintiff-appellant Walker’s success in the administrative appeal process did not cure or bar his § 1983 claim, which stated a claim for relief. Further, the Court averred that the denial of Walker’s right to call witnesses was a due process violation and his confinement thereafter was for punishment purposes. As such, defendants were liable for any damages resulting therefrom absent a successful claim of qualified immunity.

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