First Amendment Retaliation- Fourteenth Amendment Due Process Rights

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7^th Circuit Court of Appeals

Case Name: Benjamin Adams v. Christina Reagle

Case No.: 21-1730

Officials: Rovner, St. Eve, and Kirsch, Circuit Judges.

Focus: First Amendment Retaliation- Fourteenth Amendment Due Process Rights

Adams, an inmate at Indiana’s Plainfield Correctional Facility, sued both current and former commissioners of the Indiana Department of Corrections, along with several other officials, under 42 U.S.C. § 1983. Adams alleged violations of his First and Eighth Amendment rights, as well as his Fourteenth Amendment rights to due process and equal protection. Adams, sentenced to a 30-year prison term for attempted murder and an additional four years for involuntary manslaughter, initially had a job in the prison kitchen, but it was revoked due to concerns about potential drug smuggling. Subsequently, he faced charge A-100 for involvement in criminal gang activity related to a prison assault. Disciplinary Hearing Officer J. Peltier found Adams guilty of this offense on March 16, resulting in a year-long disciplinary segregation, revocation of 365 days of earned good time credits, and a demotion from credit-earning class 1 to class 3.

The Seventh Circuit upheld the district court’s decision to grant summary judgment in favor of the defendants. The appellate court determined that Adams’ claim of First Amendment retaliation lacked sufficient evidence to suggest that the defendants were motivated by retaliatory intent in pursuing the assault charge. Additionally, the court ruled that Adams was not deprived of his Fourteenth Amendment due process rights, as prison disciplinary hearings are only required to provide informal due process, affording substantial flexibility to prison administrators. On the Equal Protection claim, the court found no evidence of differential treatment based on Adams’ race. Finally, the court concluded that the defendants could not be held accountable for violating Adams’ Eighth Amendment rights, as they lacked control over the conditions of the restrictive housing where Adams was placed.

Affirmed.

Decided 01/30/24

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