Booker v. Griffin

Background

Amin Booker, who was incarcerated at Green Haven Correctional Facility in April 2015, sued Thomas Griffin, Edward Demo, Paul Chappius, Gregory Keller, and Joseph Bellnier under 42 U.S.C. § 1983. He alleged that prison officials retaliated against him for raising inmate complaints through the Inmate Liaison Committee, denied him due process in connection with his administrative-segregation hearing and later reviews, and subjected him to unconstitutional conditions during more than six years in solitary confinement.

The parties disputed why Booker was investigated and placed in administrative segregation. Booker said Griffin threatened him after he raised complaints about beatings by prison staff and then retaliated against him. The defendants said they were investigating a rumored inmate demonstration and believed Booker might have been involved. Booker also challenged the written recommendation used as notice for his administrative-segregation hearing, the evidence and procedures used at that hearing, and the reviews that continued his confinement.

The defendants moved for summary judgment on all remaining claims. Booker moved for partial summary judgment on his Fourteenth Amendment due-process claims concerning the hearing and periodic reviews, and on the defendants’ qualified-immunity and exhaustion defenses.

Rulings on Due Process

The court granted Booker summary judgment on his claim concerning the administrative-segregation hearing. It held that the written recommendation did not give him adequate notice of the alleged misconduct because it did not adequately identify the relevant date, time, place, specific conduct, or people he allegedly tried to organize. The court concluded that this prevented him from preparing an adequate defense and violated due process.

The court denied both parties’ motions for summary judgment on the periodic-review claim. It found evidence from which a reasonable fact finder could conclude that the reviews were guided by a predetermined result, relied on repeated boilerplate language, focused on Booker’s personality and remote past conduct, and failed to account meaningfully for later behavior. But the defendants presented conflicting evidence that could support a finding that the reviews were methodical and considered his conduct. The claim therefore involved genuine factual disputes.

Qualified Immunity and Exhaustion

The court granted Booker summary judgment on qualified immunity. It held that the rights involved—including rights to due process at the hearing and during administrative-segregation reviews, protection from retaliation, and protection from unjustified inhumane solitary confinement—were clearly established before the events at issue. The court rejected the defendants’ argument that their investigation, reliance on prison rules, or claimed reliance on counsel made their conduct objectively reasonable under the circumstances.

The court also granted Booker summary judgment on the defendants’ exhaustion defense. The defendants did not respond to Booker’s argument that they lacked evidence of failure to exhaust administrative remedies, so the court treated the defense as abandoned.

Conditions of Confinement

The court denied the defendants’ motion for summary judgment on Booker’s Eighth Amendment conditions-of-confinement claim. Booker had spent more than six years in solitary confinement, and the record could support a finding that the length of confinement was grossly disproportionate to the reasons given for it. The court also found a factual dispute about whether the defendants had a legitimate prison-security justification or instead continued the confinement for punitive reasons. The court did not decide that Booker had proved the claim; it held only that the claim could not be resolved for the defendants at summary judgment.

Retaliation

The court denied the defendants’ motion for summary judgment on Booker’s retaliation claim. It found that raising inmate grievances through the Inmate Liaison Committee was constitutionally protected conduct and that placement in administrative segregation for more than six years could qualify as adverse action. Evidence about the timing of the confinement, Griffin’s alleged threats, and the parties’ conflicting accounts of the investigation created a factual dispute about whether Booker’s protected activity motivated the defendants’ actions.

Injunctive Relief and Damages

The court granted the defendants partial summary judgment on injunctive relief. Booker’s requests concerning his return to the general population and changes to administrative-segregation procedures were moot because he had been released from administrative segregation. His request to prohibit retaliation was also moot because all defendants had retired from the state prison system and, according to the court, could not retaliate against him or return him to administrative segregation.

The court allowed Booker’s requests concerning the return of property and reversal or expungement of institutional records to survive. The defendants had not addressed why those requests should be dismissed, and the court treated any arguments against them as abandoned. The court denied the defendants’ motion concerning damages because the Eleventh Amendment did not bar damages claims against the defendants in their individual capacities.

Disposition

The court’s final order states that the defendants’ motion for summary judgment was denied in part and granted in part. The defendants received partial summary judgment on Booker’s requests for injunctive relief, and their motion was denied in all other respects. Booker’s motion for partial summary judgment was denied in part and granted in part: he received summary judgment on the hearing-related due-process claim and on the qualified-immunity and exhaustion defenses, while his motion was denied in all other respects. Judge Nelson S. Roman directed the clerk to terminate the two summary-judgment motions.