Vidal v. State of New York, et al.

Joseph Vidal sued New York prison officials for violating his procedural due process rights after he was unable to introduce key witness testimony during the disciplinary hearing that resulted in his placement in solitary confinement for nearly nine months. The MacArthur Justice Center took on his case to ensure that prisoners receive robust hearings before being disciplined with solitary confinement. 

After a brutal assault by prison officials, Mr. Vidal was thrown into solitary confinement and charged with initiating the assault. In the disciplinary hearing that followed, he was unable to introduce key witness testimony to corroborate his case: that he had been assaulted, not the other way around. Mr. Vidal sued New York prison officials under 42 U.S.C. § 1983 because he was deprived of due process of the law under the Fourteenth Amendment. To determine whether he was entitled to more robust procedural protections in his disciplinary hearing, a court must first consider whether the duration and conditions of the prisoner’s confinement implicate a liberty interest.  

But the district court granted summary judgment for the prison officials on the ground that the 258 days Mr. Vidal spent in solitary confinement—where he experienced lack of ventilation, excruciatingly high temperatures, and inadequate nutrition—did not impose an atypical and significant hardship on him in relation to the ordinary incidents of prison life, and therefore did not implicate a liberty interest.  

The MacArthur Justice Center represents Mr. Vidal on appeal to the U.S. Court of Appeals for the Second Circuit. We are encouraging the Court to say that—as a matter of law—long stints in solitary confinement are significant and atypical hardships and entitle people to additional procedural protections.