prisoners' rights

Beard v. Banks

Issues

What right do prisoners have to read secular publications and display photographs while serving their sentences? To what extent can prison officials infringe on this right to serve the prison’s legitimate policy goals?

 

The Long Term Segregation Unit (“LTSU”) of the State Correctional Institution at Pittsburgh, Pennsylvania was established to house “the worst of the worst” of the prison’s population. When they first enter the LTSU, inmates cannot keep newspapers, magazines, or photographs in their cells, though they have limited access to religious and legal materials. In this case, the Supreme Court will decide whether the prison’s regulation is “rationally related to a legitimate penological interest,” and therefore constitutional under the Court’s holding in Turner v. Safley. 

Questions as Framed for the Court by the Parties

Does a prison policy that denies newspapers, magazines and photographs to the most difficult inmates in the prison system in an effort to promote security and good behavior violate the 1st Amendment?

The Long Term Segregation Unit (“LTSU”) in Pittsburgh’s State Correctional Institution serves as a prison within a prison, housing inmates deemed “too disruptive, violent or problematic” to reside in the general prison population. Banks v. Beard, 399 F.3d 134, 136–137 (3rd Cir. 2005). Inmates may end up in the LTSU after unsuccessful escape attempts, assaults on guards or fellow prisoners, or incidents of sexual predation. Id.

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Howes v. Fields

Issues

Did the state court violate clearly established Supreme Court precedent, and thereby provide grounds for granting a petition for habeas corpus, by admitting statements Fields made without the benefit of Miranda warnings, while he was sequestered from the general prison population and questioned?

 

While Randall Fields was incarcerated, officers unaffiliated with the prison questioned him regarding activities unrelated to his incarceration. Fields made incriminating statements to the officers, and was convicted after these statements were admitted into evidence. The U.S. Court of Appeals for the Sixth Circuit granted Fields' petition for habeas corpus relief, holding that the state court decision was in conflict with clearly established Supreme Court precedent forbidding the admission of statements made without the protection of Miranda warnings. The Supreme Court granted certiorari to determine whether a prisoner is "in custody," and thus entitled to Miranda protections, any time the prisoner is separated from the general prison population and questioned. Petitioning Warden Carol Howes contends that habeas should not be granted because the state court’s decision is not in conflict with any clearly established precedent of the Supreme Court. In contrast, Respondent Fields argues that there is a clearly established rule granting Miranda protection to prisoners anytime they are isolated and questioned. Howes maintains that recognizing a Supreme Court precedent requiring Miranda rights to be issued any time a prisoner is questioned will grant prisoners greater protections than those given to ordinary citizens. Fields counters that requiring officers to issue Miranda warnings is essential to protecting prisoners’ Fifth Amendment rights.

Questions as Framed for the Court by the Parties

Whether this Court's clearly established precedent under 28 U.S.C. § 2254 holds that a prisoner is always "in custody" for purposes of Miranda any time that prisoner is isolated from the general prison population and questioned about conduct occurring outside the prison regardless of the surrounding circumstances.

On December 23, 2001, prison officials removed Respondent Randall Fields, who was incarcerated for disorderly conduct, from his cell and brought him to a conference room. See Fields v. Howe, 617 F.3d 813, 815 (6th Cir.

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Woodford v. Ngo

Issues

Does the rejection of a prisoner’s grievance on procedural grounds, due to the untimely nature of the claim, bar the prisoner’s constitutional claims from federal court under the Prison Litigation Reform Act’s requirement that prisoners exhaust all administrative remedies before filing suit?

 

In 2000, California state prisoner Viet Mike Ngo was placed in administrative segregation for alleged misconduct. Following his release, he was prevented from taking part in certain programs deemed critical for parole eligibility. Ngo submitted a formal grievance that was time-barred by the Appeals Coordinator because it was not filed within the requisite 15 working days after the event. Under the Prison Litigation Reform Act (“PLRA”), prisoners are prevented from filing suit until administrative remedies are exhausted. The District Court ruled that Ngo failed to exhaust his remedies under PLRA and was therefore precluded from seeking federal relief. The Ninth Circuit Court of Appeals reversed the decision, holding that Ngo exhausted all remedies as required by the PLRA. The Supreme Court will address whether an untimely administrative appeal satisfies this exhaustion requirement under PLRA.

Questions as Framed for the Court by the Parties

Does a prisoner satisfy the Prison Litigation Reform Act’s administrative exhaustion requirement by filing an untimely or otherwise procedurally defective administrative appeal?

Respondent Viet Mike Ngo is a prisoner serving a life sentence in California. Brief for the United States as Amicus Curiae Supporting Petitioners, at 1. On October 26, 2000, Ngo, an inmate at San Quentin State Prison, was placed in administrative segregation as punishment for alleged “inappropriate activity” with Catholic volunteer priests. Brief for Respondent at 2, .

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