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Clinton D. Davis v. Mason Waters, Warden, MCI
Citations: 59 F.3d 166; 1995 U.S. App. LEXIS 23404; 1995 WL 371680Docket: 92-6208
Court: Court of Appeals for the Fourth Circuit; June 20, 1995; Federal Appellate Court
Clinton D. Davis filed a lawsuit under 42 U.S.C.A. § 1983, alleging that Mason Waters, the Warden of the Maryland Correctional Institute-Hagerstown (MCI-H), violated his Fourteenth Amendment right to due process by finding him guilty of disciplinary infractions without sufficient evidence. Davis appealed the district court's decision granting summary judgment in favor of Waters. The background involves a significant prison riot in May 1991, where approximately 1,000 of 1,200 inmates participated. Following the riot, Davis was found outside his assigned cell and charged with three infractions related to prison rules prohibiting wrongful conduct, participation in disturbances, and being absent from assigned areas without permission. During the disciplinary hearing, Davis admitted to leaving his cell but stated he did so out of fear for his safety. No evidence was presented to demonstrate his active participation in the riot. The hearing officer determined that Davis violated two rules, resulting in a 180-day punitive segregation sentence and the loss of 60 days of good-time credit for the first violation, with an additional 40 days of concurrent segregation for the second. Waters endorsed these decisions. The court assessed whether the district court correctly granted summary judgment by analyzing if there was “some evidence” to support the disciplinary findings against Davis, as established by precedents. It was acknowledged that Davis had a protected liberty interest in his good-time credits and freedom from punitive segregation. The standard requires that any deprivation of liberty must be supported by at least some evidence, allowing for a determination of the sufficiency of evidence in the record. Davis contends that the evidence was inadequate to support violations of Rules 3 and 19. However, it is established that he was found outside his cell after the prison was secured post-riot, and he admitted to leaving his assigned cell. This admission provides sufficient evidence for a violation of Rule 19. Regarding Rule 3, Davis's departure from his cell during the riot also supports the conclusion that he participated in the disturbance, as such actions hinder efforts to control the situation. The court affirms that the summary judgment granted to Waters was appropriate. Furthermore, Waters' use of a sentencing override provision did not infringe upon Davis' due process rights, as the evidence of his actions during the riot justified the decision related to the incident causing harm to both staff and inmates.