No damages claim for inmate who remained in jail after his release date

This case tells us something about qualified immunity. The Court of Appeals finds that an inmates Eighth Amendment rights were violated because he remained incarcerated beyond his release date. But the Court also finds that the defendant cannot be sued because the inmate's rights were not clearly established at the time.

The case is Hurd v. Fredenburgh, issued on January 12. Plaintiff was sentenced for various misdemeanors. A complex formula governs prison sentences, taking into account concurrent sentences and possible early release depending on whether the inmate served time on the charge while awaiting trial. Inmates may also be eligible for "good time," which allows for early release for good behavior. In this case, even after plaintiff got a release date for April 19, 2016, he remained incarcerated for nearly a year. Plaintiff claims that prison officials reduced his jail-time credit to prevent his release. The Court of Appeals notes that plaintiff did not provide a motive for this.

The district court dismissed the case, holding that plaintiff did not identify an Eighth Amendment violation. The Court of Appeals disagrees. "Unauthorized detention of just one day past an inmate's mandatory release date qualifies as a harm of constitutional magnitude under the first prong of the Eighth Amendment analysis. Hurd's unauthorized imprisonment for almost one year certainly qualifies under that standard." This is because Hurd's release was mandatory under New York law. So why doesn't Hurd win the appeal?

Hurd loses on qualified immunity grounds, which lets government defendants off the hook if they do not violate clearly-established case law that specifically held their actions were illegal. The Court begins is analysis by noting that if prolonged detention in jail results from mistakes made in good faith, mistake, or processing or other administrative delays made in good faith, then there is no deliberate indifference under the Eighth Amendment. After pausing to consider (1) the defendant in this case was deliberately indifferent to Hurd's rights or whether she was powerless to do anything about it (since the City made the calculations), or (2) whether there was a due process liberty-interest violation, the Second Circuit holds that she is entitled to qualified immunity"it was not clearly established during the period of Hurd's prolonged detention that an inmate suffers harm of a constitutional magnitude under the Eighth Amendment when they are imprisoned past their mandatory conditional release date, nor was it clearly established that an inmate has a liberty interest in mandatory conditional release protected by the Fourteenth Amendment's substantive due process clause." 

Plaintiff tried to get around the qualified immunity hurdle by arguing that existing cases "confirm a uniform legal principle that no federal, state, or local authority can keep an inmate detained past the expiration of the sentence imposed on them." But those case provide a general rule. "None of the cases upon which Hurd relies addresses a conditional release scheme, let alone one in which an inmate is entitled to mandatory release prior to the expiration of their maximum sentence. More to the point, none of them confirm that prolonging an inmate's detention past their conditional release date might violate the inmate's rights under the Eighth Amendment."

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