Johnson, Jr. v. Maguire Correctional Facility

Background

Larvester J. Johnson, Jr., a pretrial detainee at Maguire Correctional Facility, brought a civil-rights lawsuit under 42 U.S.C. § 1983. He alleged that jail officials violated his Fourteenth Amendment right to due process by placing him in administrative segregation without written notice of charges or an adversarial hearing.

On July 11, 2017, Johnson became confrontational with Sheriff’s Correctional Officer Rachel Recoder after she identified his stamps and envelopes as contraband. During an inspection of his housing unit, Johnson yelled obscenities at Recoder and her partner. Other inmates argued with Johnson, and he threatened to fight them. Staff moved him to a holding cell. Recoder reported the incident to the Classification Unit but did not have authority to place Johnson in administrative segregation. After entering the holding cell, Johnson flooded it and threw wads of toilet paper onto its windows. He was then placed in administrative segregation. Later that evening, he received a disciplinary write-up that resulted in the loss of two weeks of commissary privileges.

Defendants moved for summary judgment, a ruling issued when the evidence shows no genuine dispute over facts that could affect the result and the moving party is entitled to judgment as a matter of law. Johnson did not oppose the motion. The court explained that it could not grant the motion solely because he failed to respond; it had to review the defendants’ evidence and determine whether a genuine factual dispute existed.

Rulings on the Claims

As to Recoder, the court granted summary judgment because the undisputed evidence showed that she only reported Johnson’s behavior and recommended that he be removed from the housing unit. She lacked authority to place him in administrative segregation.

As to Sergeant Julie Costa, the court held that Johnson’s placement was administrative rather than disciplinary. For a pretrial detainee, a restriction imposed for punishment implicates due process, but a restriction reasonably related to a legitimate governmental objective—such as maintaining jail order and security—is not punishment without more. The evidence showed that Costa approved Johnson’s initial placement to maintain order, safety, and security, not to punish him. The jail’s policy allowed administrative segregation for those reasons but not for punishment or discipline.

The court also noted that an administrative-segregation report stated the reasons for Johnson’s placement, jail policy required that he receive a copy, and he could use the jail grievance procedure to express disagreement. Costa was responsible only for the initial placement, not Johnson’s continued retention in segregation. The record contained no evidence that the jail’s policies were unnecessary or unjustified. The court therefore granted summary judgment for Costa.

Qualified Immunity

Qualified immunity protects government officials from liability unless their conduct violated a constitutional right that was clearly established at the time. The court held that both defendants were entitled to qualified immunity. Recoder did not place Johnson in segregation and lacked authority to do so. Costa placed him there for order and security rather than punishment, followed the jail’s procedures, and did not violate Johnson’s due-process rights.

The court further held that, even if a fact dispute existed about whether the placement violated due process, the defendants would still receive qualified immunity because it was not clearly established that a pretrial detainee had a right to a specific procedure, such as a formal adversarial hearing, before being placed in non-disciplinary administrative segregation.

Disposition

The court granted defendants’ motion for summary judgment. It ordered the clerk to terminate pending motions and close the file.