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Wilkinson v. Austin
United States Supreme Court
545 U.S. 209 (2005)
Reginald Wilkinson (defendant) was the director of Ohio’s prison system. Charles Austin (plaintiff) was an inmate in the prison system’s maximum-security Ohio State Penitentiary (OSP). The OSP housed only the prison system’s most predatory and dangerous prison inmates and confined those inmates under the prison system’s harshest restrictions. In other Ohio prisons, inmates in solitary confinement might experience some of those restrictions for days or weeks at a time. By contrast, OSP inmates experienced the restrictions full-time and indefinitely. Moreover, OSP inmates lost any eligibility they might otherwise have for parole. When the prison system adopted a new policy to determine how inmates were assigned to or released from the OSP, Austin sued Wilkinson in federal court. Austin alleged that the new policy violated Austin’s constitutional right to procedural due process. The district court found that although Austin had a protected liberty interest in avoiding assignment to the OSP, the new policy met all constitutional requirements. The Sixth Circuit Court of Appeals agreed as to the existence of a liberty interest but ordered certain modifications to the prison’s new policy. Wilkinson appealed to the United States Supreme Court.
Rule of Law
Holding and Reasoning (Kennedy, J.)
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