Inmate wins one claim, loses another, on appeal

This case involves an inmate who was placed in administrative segregation after he was brutally attacked by other inmates. He remained in the special housing unit for quite some time, and he claims jail officials did not properly review the appropriateness of this assignment in violation of the due process clause. What complicates matters was that plaintiff was originally incarcerated in Connecticut but was transferred to Virginia. Plaintiff says that Connecticut failed to conduct this review while he was in Virginia's custody.

The case is Baltas v. Maiga, issued on October 11. As the Court of Appeals (Parker, Lohier and Nathan) notes, "Baltas was never confined in a Connecticut prison during the time that he alleges that [Connecticut prison officials] failed to review his Connecticut [Administrative Segregation] classification. In a due process case like this, the court determines whether the state afforded plaintiff a fair procedure, bearing in mind that prison officials have some flexibility in how they run their affairs.

The record shows that Connecticut conducted four regular classification reviews of plaintiff's status when he was in Virginia, analyzing such relevant factors as plaintiff's history as an inmate, severity or violence of his offense, etc. Connecticut's classification reviews satisfy minimal due process standards, the Court holds, as the reviews considered his potential for violence, etc., and accounted for any new information about plaintiff in determining whether to adjust his "risk scores." The due process claim fails.

But plaintiff's other claim succeeds on appeal. He argues that he endured bad jail conditions by Virginia prison officials. While plaintiff did not fully comply with the grievance process, a necessary step prior to any lawsuit, he claims that jail officials threatened him out of exhausting all his administrative remedies. If the trial court believes plaintiff's sworn testimony, it may find that he was dissuaded from fully complying with the grievance process because of these threats. In finding otherwise, the district court granted summary judgment in violation of the principle that trial courts "should not engage in searching, skeptical analyses of parties' testimony in opposition to summary judgment." The cite for that is Rivera v. Genesee Reg'l Transp. Auth., 743 F.3d 11, 20 (2d Cir. 2014). As plaintiff's sworn account of these threats is enough to identify a disputed factual issue about possible dissuasion, summary judgment was improper on the issue of whether the Virginia grievance process was available to plaintiff.