ALONZO FLOYD CLARK, APPELLANT,
v.
LOUIE L. WAINWRIGHT, APPELLEE
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Clark, an inmate at Florida State Prison, challenged his placement in administrative confinement and close management status via habeas corpus, asserting prison officials violated due process by failing to provide proper hearings. The court affirmed the dismissal, finding that although procedural defects existed in the administrative confinement placement, the subsequent valid placement in close management rendered the administrative confinement claim moot and did not warrant habeas relief.
Although the court acknowledged that prison officials failed to comply with procedural requirements for administrative confinement placement, habeas corpus relief was properly denied because: (1) the subsequent valid placement in close management made the administrative confinement claim moot; (2) administrative confinement is not a prerequisite to close management; and (3) granting relief would not enable Clark to return to the general prison population.
[1] State administrative procedures that create a liberty interest in an inmate remaining in the general prison population must be followed to avoid violating due process rig…
[2] Placement of an inmate in administrative confinement is not a prerequisite to placement in close management status.
Previewing 2 of 4 headnotes on this case. FLexlaw’s editorially structured points of law — every proposition, pinpointed — are reserved for members.
Join FLexlaw to unlock all legal intelligence“state administrative procedures required for placing an inmate on administrative confinement and its subcategory "close management" generate a liberty interest in an inmate remaining in the general prison population”
Establishes that prison procedures create a protected constitutional interest, requiring compliance with due process.
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Join FLexlaw to unlock all legal intelligenceClark was placed in administrative confinement following his involvement in a fighting incident in which another inmate suffered multiple stab wounds.…
The full statement of facts, procedural history, and disposition for this case are member content.
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WILLIS, BEN C. (Ret.), Associate Judge.
This cause was initiated by Clark’s filing of a petition for writ of habeas corpus in the Circuit Court of the Eighth Judicial Circuit. In his petition, Clark asserted that he is a prisoner at Florida State Prison and that he was placed in adminstrative confinement and subsequently in close management status in violation of his due process rights. Specifically, Clark complains that prison officials failed to grant him a pre or post administrative hearing for his placement in confinement and failed to advise him of the reason why he was removed from the general prison population in accordance with Rule 38-3.081(4), Florida Administrative Code.
On 26 July 1985, the trial judge entered an order dismissing Clark’s petition. The order concluded that the documents provided by the State in connection with their response to Clark’s petition demonstrated that he was not entitled to the relief which he sought. We affirm.
Clark was placed in administrative confinement due to his involvement in a fighting incident in which another inmate suffered multiple stab wounds. The applicable rule, Section 33-3.081(5)(a), Fla.Admin. Code, provides that any inmate placed in administrative confinement shall be given a hearing and an opportunity to present any facts or arguments relevant to his placement in such confinement. From the report filed in this case, it can be seen that Clark was interviewed by a correctional officer and given an opportunity to make a statement, but that a hearing was not held.
Clark was subsequently placed on close management status. However, prior to this a hearing was held by the close management assignment team at which Clark was allowed to be present. Placement of inmates on close management is governed by Section 33-3.083(4), Fla.Admin.Code, which like the other rule requires a hearing and an opportunity to be heard.
From the above, it can be seen that this case presents an interesting dilemma, to-wit: what relief, if any, should an inmate be granted when the procedure required to place him in administrative confinement has not been met, but the procedure required to place him in the more restrictive confinement of close management has been met?
It has been determined that state administrative procedures required for placing an inmate on administrative confinement and its subcategory “close management” generate a liberty interest in an inmate remaining in the general prison population. Adams v. Wainwright, 512 F.Supp. 948 (N.D. Fla. 1981). Otherwise stated, when policies and procedures are instituted by the Department of Corrections, they must be followed or a due process right is violated. Granger v. Florida State Prison, 424 So. 2d 937 (Fla. 1st DCA 1983).
Accordingly, we are concerned with the failure of prison officials to comport with the mandates of the administrative confinement rule. However, we find we must affirm the trial court’s denial of Clark’s petition for the reason that once Clark was placed in close management status, any complaints as to his placement in administrative confinement became moot. Placement in administrative confinement is not a prerequisite to placement in close management. Therefore, any error in the procedure employed for the first should not be seen to taint the latter. Further, since Clark was validly placed in close management status, granting his petition for habe-as corpus relief or instructing an evidentia- ry hearing on the petition would still not enable him to return to the prison’s general population.
Affirmed.
NIMMONS and WENTWORTH, JJ., concur.
Cases With Similar Vibessemantic neighbors from the corpus
Citator
Cited By
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Melvin v. State, 804 So. 2d 460 (Fla. 2d DCA 2001)…ter being afforded due process. See, e.g., S.J. v. State, 596 So. 2d 1181, 1182 n. 1 (Fla. 5th DCA 1992) (observing that when juvenile pleaded guilty to delinquency charge the illegality of his prehearing detention became moot); Clark v. Wainwright, 490 So. 2d 1055, 1056-57 (Fla. 1st DCA 1986) (holding that inmate who was . placed in administrative confinement without required hearing was not entitled to habeas corpus relief because he was later placed in more restrictive close management status after a hearin…
Authorities Cited
- Granger v. Fla. State Prison & Bill Price, 424 So. 2d 937 (Fla. 1st DCA 1983)
- Adams v. Wainwright, 512 F. Supp. 948 (N.D. Fla. 1981)