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Dixon v. State
Citations: 513 So. 2d 37; 1986 Ala. Crim. App. LEXIS 7369Docket: 8 Div. 606
Court: Court of Criminal Appeals of Alabama; December 29, 1986; Alabama; State Appellate Court
Alvin Dixon, an inmate on work release, was found with a bottle of rum and subsequently removed from the work release program, leading to a charge of violating Rule No. 64 regarding contraband. The Disciplinary Board requested a review by social services for a potential custody change but did not acknowledge that Dixon had already experienced a custody change due to his removal from the work release program. The state argues that Dixon's removal was either not a consequence of possessing contraband or that it did not significantly alter his conditions of confinement, thus not requiring due process protections. Citing precedent from Summerford v. State and Spooner v. State, the court determined that if a major change occurred in Dixon's confinement conditions, due process must be afforded. The court granted a summary judgment on the habeas corpus petition without a hearing but found it necessary to remand the case back to the circuit court for a hearing to establish whether there was indeed a major change in conditions and to address due process issues raised by Dixon. The decision was reversed and remanded with instructions, with all judges concurring.