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Richard Dee Thomas v. Ignacio Briones, Individually and in His Capacity as an Out-Court Coordinator for Utah State Prison Colleen Gabbitas, Individually and in Her Capacity as an Executive Officer for the Utah State Prison Lynn Jorgensen, Individually and in His Capacity as a Warden at the Utah State Prison Ken Halterman, Individually and in His Capacity as a Corrections Investigator for the Department of Corrections Blake Nielsen, Individually and in His Capacity as the Classification Officer at the Utah State Prison Rick Rasmussen, Individually and in His Capacity as an Fbi Agent for the State of Utah Jeff Galli, Individually and in His Capacity as an Employee for the Department of Corrections Andrew Hunt, Individually and in His Capacity as a Case Worker for the Department of Corrections Roxanne Bennett, Individually and in Her Capacity as an Employee for the Utah Department of Corrections

Citations: 35 F.3d 574; 1994 U.S. App. LEXIS 32442; 1994 WL 482978Docket: 94-4112

Court: Court of Appeals for the Tenth Circuit; September 7, 1994; Federal Appellate Court

Narrative Opinion Summary

In this case, a Utah state prisoner appealed the dismissal of his pro se action under 42 U.S.C. § 1983, alleging that the defendants failed to provide him with special protection and housing after he acted as an informant. The Tenth Circuit reviewed the appeal without oral argument. The claims against the federal defendant were dismissed because the plaintiff did not show that the defendant acted under color of state law, and the defendant was also entitled to qualified immunity. The state defendants were dismissed as they had not participated in the plaintiff's classification, and no evidence indicated a breach of any agreement regarding his incarceration. The magistrate judge determined that prisoners do not have a liberty interest in their classification absent a clear promise, which was not found here. The court affirmed the district court's judgment, upholding the magistrate judge's findings and recommendations. The ruling may be cited under certain conditions, although it is not binding precedent.

Legal Issues Addressed

Breach of Agreement in Prisoner Classification

Application: The plaintiff's claims against state defendants were dismissed due to lack of evidence of a breach of any agreement regarding his incarceration.

Reasoning: The state defendants were dismissed on grounds that they either did not participate in Thomas' classification or that there was no evidence of a breach of any agreement regarding his incarceration.

Liberty Interest in Prison Classification

Application: The court found that prisoners do not have a liberty interest in their classification unless there is a clear promise regarding classification, which was not present in this case.

Reasoning: The magistrate judge ruled that prisoners do not possess a liberty interest in their institutional classification unless a clear promise regarding such classification is made, which was not the case here.

Qualified Immunity for Federal Defendants

Application: The federal defendant was entitled to qualified immunity, which protected them from the plaintiff's claims under Section 1983.

Reasoning: The federal defendant’s claims were dismissed because... the federal defendant was entitled to qualified immunity.

Requirements for Section 1983 Claims

Application: In this case, the plaintiff's claims against the federal defendant were dismissed because he failed to demonstrate that the defendant acted under color of state law.

Reasoning: The federal defendant’s claims were dismissed because Thomas did not demonstrate that the defendant acted under color of state law, a necessary requirement for § 1983 claims.