SLAUGHTER v. BEAN (2021)

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

Summary · law.co

Holding. The court affirmed the district court's summary judgment, concluding that Slaughter failed to establish a genuine factual dispute regarding whether prison officials violated his due process rights at the disciplinary hearing.

Rickie Slaughter, a Nevada state prisoner, appealed a district court's grant of summary judgment in his federal civil rights action under 42 U.S.C. § 1983, in which he claimed that prison officials violated his due process rights during a disciplinary hearing. The appellate court reviewed the case without deference to the district court's conclusions and found that Slaughter had failed to present evidence sufficient to create a genuine dispute about whether officials had denied him the process he was constitutionally entitled to receive. The court noted that due process protections in prison disciplinary settings require only that some evidence support the disciplinary decision, and that prison authorities retain discretion to exclude witness testimony based on considerations such as relevance, necessity, or institutional safety concerns.

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

Key issues

Due process protections in prison disciplinary proceedings
Sufficiency of evidence to support a disciplinary decision
Prison officials' discretion to exclude witness testimony

Procedural posture

Slaughter appealed pro se from a district court's grant of summary judgment dismissing his § 1983 due process claim.

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.