Chappell v. Mandeville

When the law is not clearly established on whether a contraband watch violates the Eighth Amendment, such that it fails to provide adequate notice to prison officials regarding the constitutionality of their actions, the prison officials are entitled to qualified immunity.

Prison officials Mandeville and Rosario (Defendants) appealed the district court’s decision denying part of their motion for summary judgment. Specifically, the district court denied the motion with regard to Chappell’s claims that (1) a contraband watch (also called a “body cavity search”) constituted cruel and unusual punishment in violation of the Eighth Amendment, and (2) his “due process rights were violated since he was not given notice of the charges against him or an opportunity to be heard prior to being placed on contraband watch.” Chappell alleged that he was subjected to twenty-four-hour lighting and mattress deprivation, and that “he was taped into two pairs of underwear and jumpsuits, placed in a hot cell with no ventilation, chained to an iron bed, shackled at the ankles and waist so that he could not move his arms, and was forced to eat like a dog.” In concluding that Defendants were entitled to qualified immunity, the Court determined that when the watch took place, Defendants lacked fair notice of whether their actions were unconstitutional. It reasoned that no court rulings addressed whether the contraband watch “constitutes a legitimate penological purpose” justifying the continuous lighting, and the law was unclear regarding mattress deprivation. As to the combination of conditions, the Court reasoned that “no court had held that conditions similar to those Chappell experienced were unconstitutional in the face of the important penological purpose of discovering contraband.” With regard to Chappell’s due process claim, in considering an inmate’s “narrow range” of protected liberty interests, the contraband-watch conditions were “within the sentence imposed upon him.” The Court stated that, “[a]n investigative contraband watch is the type of condition of confinement that is ordinarily contemplated by the sentence imposed.” Therefore, “Chappell cannot claim a liberty interest under the Due Process Clause of the Fourteenth Amendment.” REVERSED.