Cleavinger v. Saxner
1985 U.S. LEXIS 148, 88 L. Ed. 2d 507, 474 U.S. 193 (1985)
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Rule of Law:
Members of a federal prison's Institution Discipline Committee who conduct inmate hearings are not entitled to absolute judicial immunity from damages for constitutional violations, but are instead protected by qualified immunity.
Facts:
- David Saxner and Alfred Cain, Jr. were inmates at a federal prison in Terre Haute, Indiana.
- Following the death of a fellow inmate, a work stoppage occurred at the prison.
- Saxner and Cain, who claimed they did not participate in the stoppage, gathered information about the inmate's death and medical conditions at the prison and disseminated it to the press, Members of Congress, and prison officials.
- Prison officials cited both Saxner and Cain in Incident Reports for encouraging other inmates to engage in the work stoppage.
- Both inmates were immediately placed in administrative segregation.
- An Institution Discipline Committee, composed of prison officials Theodore Cleavinger, Marvin Marcadis, and Tom P. Lockett, held hearings for Saxner and Cain.
- The committee found both inmates guilty of encouraging a work stoppage and other uncharged offenses.
- The committee sanctioned both inmates with placement in administrative detention, forfeiture of "good time" credits, and a recommendation for transfer to another prison.
Procedural Posture:
- Respondents Saxner and Cain appealed the committee's decision to the Warden, who restored their good time credits and ordered their release from administrative detention.
- Respondents then appealed to the Regional Director of the Bureau of Prisons, who ordered that the entire incident be expunged from their records.
- Respondents filed a Bivens action in the U.S. District Court for the Southern District of Indiana against Petitioners (the committee members), alleging constitutional violations and seeking damages.
- The District Court initially granted petitioners' motion to dismiss on grounds of absolute immunity, but later reinstated the suit on reconsideration.
- The case proceeded to a jury trial, where the jury found that petitioners had violated respondents' Fifth Amendment due process rights and awarded compensatory damages.
- Petitioners appealed to the U.S. Court of Appeals for the Seventh Circuit, arguing they were entitled to absolute immunity.
- A divided panel of the Seventh Circuit affirmed the district court's judgment, holding that the committee members were only entitled to qualified immunity.
- The Supreme Court of the United States granted certiorari.
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Issue:
Are members of a federal prison's Institution Discipline Committee entitled to absolute immunity from personal damages liability for actions taken in their official capacity that violate the United States Constitution?
Opinions:
Majority - Justice Blackmun
No, members of a federal prison's Institution Discipline Committee are not entitled to absolute immunity; they are protected only by qualified immunity. The Court applied a 'functional' approach, analyzing the nature of the officials' responsibilities rather than their title. While the committee members perform an adjudicatory function, they lack the 'classic' characteristics of the judicial process that justify absolute immunity. They are not independent, but are instead prison officials and subordinates of the warden who reviews their decisions, creating pressure to resolve disputes in favor of the institution. The procedural safeguards present in their hearings are far less robust than those in a formal judicial proceeding, lacking rights to counsel, cross-examination, discovery, or a verbatim transcript. The Court analogized the committee members to the school board members in Wood v. Strickland, who also performed adjudicatory functions but were only granted qualified immunity.
Dissenting - Justice Rehnquist
Yes, the members of the Institution Discipline Committee should be entitled to absolute immunity. The dissent argues that the majority fails to properly weigh the unique and volatile prison environment. Unlike administrative law judges, committee members operate in a tense setting where inmates, who are prolific litigants with little to lose, are likely to file harassing lawsuits. The dissent contends that the risk of personal liability would deter officials from making necessary disciplinary decisions. Furthermore, the availability of a swift and effective administrative appeals process, which fully vindicated the inmates in this very case, provides a sufficient check on unconstitutional conduct and reduces the need for private damages actions.
Analysis:
This decision solidifies the Supreme Court's 'functional approach' to immunity, emphasizing that the mere performance of adjudicatory tasks does not automatically confer absolute judicial immunity. By denying absolute immunity to prison disciplinary officials, the Court clarified that independence from institutional pressure and the presence of robust procedural safeguards are critical prerequisites for such protection. This holding ensures that prisoners retain a meaningful remedy for due process violations in disciplinary hearings, while still affording officials qualified immunity, which protects them from liability unless they violate clearly established constitutional law. The case sets a precedent that will likely be applied to other quasi-judicial bodies within the executive branch.
