SLAUGHTER v. BEAN (2021)

United States Court of Appeals, Ninth Circuit.2021-09-22No. No. 20-15335

Summary · law.co

Holding. The district court's summary judgment in favor of the prison officials was affirmed because the prisoner failed to create a genuine issue of material fact regarding whether he was denied constitutionally required due process at his disciplinary hearing.

Rickie Slaughter, an inmate in Nevada, filed a federal civil rights lawsuit under 42 U.S.C. § 1983 claiming that prison officials violated his due process rights during a disciplinary hearing. The district court granted summary judgment against him, finding no genuine factual dispute on the merits. The appellate court reviewed the case fresh and upheld the lower court's decision.

The court concluded that Slaughter presented no credible evidence suggesting prison officials failed to provide the process required by law. Under established precedent, disciplinary decisions in prison settings need only be supported by some evidence, and prison authorities retain discretion over matters such as witness testimony, including decisions to exclude witnesses based on irrelevance, lack of necessity, or safety concerns.

Summary generated by law.co from the public-domain opinion. The opinion text itself is public domain.

Key issues

Whether prison disciplinary procedures afforded constitutionally adequate due process
Whether summary judgment was properly granted when prisoner presented insufficient evidence of due process violation
Standard of review for prison disciplinary decisions under the due process clause

Procedural posture

The inmate appealed pro se from the district court's grant of summary judgment in a § 1983 civil rights action challenging a prison disciplinary hearing.

Authorities cited

No cited authorities resolved to law.co cases yet.

Opinion · public domain

MEMORANDUM **

Nevada state prisoner Rickie Slaughter appeals pro se from the district courts summary judgment in his 42 U.S.C. § 1983 action alleging due process violations arising from a disciplinary hearing. We have jurisdiction under 28 U.S.C. § 1291. We review de novo. Furnace v. Sullivan, 705 F.3d 1021, 1026 (9th Cir. 2013). We affirm.

The district court properly granted summary judgment because Slaughter failed to raise a genuine dispute of material as to whether prison officials failed to afford him all of the process that he was due. See Superintendent v. Hill, 472 U.S. 445, 454, 105 S.Ct. 2768, 86 L.Ed.2d 356 (1985) (requirements of due process are satisfied if “some evidence” supports disciplinary decision); Wolff v. McDonnell, 418 U.S. 539, 563-71, 94 S.Ct. 2963, 41 L.Ed.2d 935 (1974) (setting forth due process requirements in prison disciplinary proceedings and explaining that prison authorities have discretion not to call witnesses, “whether it be for irrelevance, lack of necessity, or the hazards presented in individual cases”).

AFFIRMED.