Cleavinger v. Saxner

Background

Two inmates at the federal prison in Terre Haute, Indiana, gathered and passed information about a fellow inmate’s death and were later charged with encouraging a work stoppage. Each was placed in administrative segregation after a February 1975 hearing before a three-member Institution Discipline Committee. The committee found both guilty, ordered detention and forfeiture of “good time,” and recommended transfer. The Warden and then the Regional Director later reversed or expunged the sanctions, but the inmates sued in federal court seeking damages for constitutional violations.

Reasoning

The Court asked whether committee members are entitled to absolute immunity from damages like judges or administrative law judges. Applying a functional test, the majority noted important differences: committee members were prison employees, not independent adjudicators; hearings lacked key safeguards (no lawyer, no right to compel witnesses or cross-examine, no verbatim transcript); and decisions were subject to warden review. Given these facts, the Court held that absolute immunity was not warranted. Instead, committee members have only qualified immunity, meaning they can face damages suits when they violate clearly established constitutional rights.

Real world impact

The decision allows inmates to sue prison hearing officers for constitutional violations while still giving officers some protection unless they knowingly or plainly acted outside constitutional limits. The ruling affirms lower-court findings for the two inmates and makes clear that prison disciplinary officials must follow basic due-process protections to avoid liability.

Dissents or concurrances

A dissent argued the prison context, quick administrative remedies, and volatile environment favored absolute immunity to protect officials from harassment, but that view did not carry the majority.