Case: Bills v. Henderson

3:77-00165 | U.S. District Court for the Eastern District of Tennessee

Filed Date: May 2, 1977

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Case Summary

In 1977, inmates at the Brushy Mountain State Penitentiary filed a lawsuit under 42 U.S.C. § 1983 against the Tennessee Department of Corrections and the warden of the prison in the U.S. District Court for the Eastern District of Tennessee. The plaintiffs alleged that their constitutional rights had been violated by a lack of due process in prison disciplinary proceedings, which resulted in a loss of good time, and they asked the court to grant them declaratory and injunctive relief as well as…

In 1977, inmates at the Brushy Mountain State Penitentiary filed a lawsuit under 42 U.S.C. § 1983 against the Tennessee Department of Corrections and the warden of the prison in the U.S. District Court for the Eastern District of Tennessee. The plaintiffs alleged that their constitutional rights had been violated by a lack of due process in prison disciplinary proceedings, which resulted in a loss of good time, and they asked the court to grant them declaratory and injunctive relief as well as damages. On February 24, 1978, the U.S. District Court for the Eastern District of Tennessee (Judge Robert Taylor) denied class certification to the plaintiffs, dismissed the Department of Corrections as a defendant to the suit, and granted injunctive relief to the plaintiffs. The court held that failure to provide inmates a limited written record of the hearing wherein the orders were entered placing them in punitive segregation and depriving them of good time did deprive them of due process. However, the court refused to award punitive damages or restoration of good time to the plaintiffs. Bills v. Henderson, 446 F.Supp. 967 (E.D.Tenn. 1978). The plaintiffs appealed.

On October 1, 1980, the U.S. Court of Appeals for the Sixth Circuit (Judge Cornelia Kennedy, Judge George Edwards, and Judge Paul Weick) affirmed in part and reversed in part. The Sixth Circuit held that: (1) the inmates were not afforded their full due process rights prior to transfer to administrative or punitive segregation; (2) that under guidelines applicable at the state prison, inmates had a right to certain procedural protections prior to transfer to administrative or punitive segregation; (3) that when a transfer to administrative segregation is made in response to a finding that the prisoner broke the rules, the prisoner is entitled to a written statement of the evidence relied on and the reasons for the transfer; (4) that when the transfer is based on a determination that it will protect the transferred inmate and other inmates, as well as maintaining order, then the inmate is entitled to notice which is specific enough to inform him of the facts which triggered the charges and to enable him to marshal evidence on his own behalf; (5) that expunging the inmates' records in this case was not an appropriate remedy; (6) that the inmates were not entitled to restoration of good time; and (7) that the inmates could not recover damages. Bills v. Henderson, 631 F.2d 1287 (6th Cir. 1980).

Summary Authors

Kristen Sagar (5/5/2006)

People


Judge(s)

Kennedy, Cornelia Groefsema (Michigan)

Attorney for Plaintiff

Nickle, Carol S. (Tennessee)

Attorney for Defendant

Cottrell, Patricia J. (Tennessee)

Hildebrand, Henry E. III (Tennessee)

McLemore, Brooks (Tennessee)

Judge(s)

Kennedy, Cornelia Groefsema (Michigan)

Taylor, Robert Love (Tennessee)

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Documents in the Clearinghouse

Document

3:77-00165

Memorandum

Feb. 24, 1978

Feb. 24, 1978

Order/Opinion

446 F.Supp. 446

78-01172

Reported Opinion

U.S. Court of Appeals for the Sixth Circuit

Oct. 1, 1980

Oct. 1, 1980

Order/Opinion

631 F.2d 631

Docket

Last updated March 25, 2024, 3:05 a.m.

Docket sheet not available via the Clearinghouse.

Case Details

State / Territory: Tennessee

Case Type(s):

Prison Conditions

Key Dates

Filing Date: May 2, 1977

Case Ongoing: No reason to think so

Plaintiffs

Plaintiff Description:

Inmates at the Brushy Mountain State Penitentiary.

Public Interest Lawyer: Unknown

Filed Pro Se: Unknown

Class Action Sought: Yes

Class Action Outcome: Denied

Defendants

Tennessee Department of Corrections, State

Case Details

Causes of Action:

42 U.S.C. § 1983

Constitutional Clause(s):

Due Process

Available Documents:

Any published opinion

Outcome

Prevailing Party: Mixed

Nature of Relief:

Injunction / Injunctive-like Settlement

Source of Relief:

Litigation

Order Duration: 1978 - None

Issues

General:

Disciplinary procedures

Personal injury

Jails, Prisons, Detention Centers, and Other Institutions:

Administrative segregation

Disciplinary segregation

Good time

Assault/abuse by non-staff (facilities)

Type of Facility:

Government-run