United States Court of Appeals For the Seventh Circuit
Civil Rights — due process — pretrial detention
Defendants did not unconstitutionally fail to protect an inmate by placing him in a maximum-security cellblock.
“When pressed at oral argument to identify a specific problem with the classification system, Smith’s attorney suggested that the policy should have placed more weight on the nature of the charge that brought the inmate into the jail. But there is no reason to think that considering other factors in addition to the severity of an inmate’s current charge is unreasonable. On the contrary, an inmate’s criminal record and institutional history are plainly appropriate factors to consider in classifying inmates by security risk. Cf. Bell v. Wolfish, 441 U.S. 520, 547 (1979) (explaining the need for ‘wide-ranging deference’ to prison administrators ‘in the adoption and execution of policies and practices that in their judgment are needed to preserve internal order and discipline and to maintain institutional security’). Indeed, the failure to consider other relevant factors beyond the inmate’s current charge could obscure a propensity toward violent behavior. An inmate’s misbehavior during arrest or past inability to function in multiple-inmate cellblocks could easily be a sign of trouble; jail administrators are entitled to infer as much and assign ‘special problems’ status to inmates with these characteristics. The inmate’s criminal record is obviously important; Smith does not argue otherwise. He criticizes the classification policy for the weight it assigns to warrants, parole holds, and gang affiliation, but he has no evidence that these features of the system are unsound or irrelevant to jail safety concerns.”
Appeal from the United States District Court for the Central District of Illinois, Cudmore, Mag. J., Sykes, J.