Hamner v. Burls

Charles Hamner warned a corrections officer that another inmate was planning to attack one of the prison guards. The prisoner planning the attack was apprehended.

Following the incident, corrections officers put Mr. Hamner in solitary confinement.

No reason was ever provided for the officials’ decision. The first “7-day review” of his placement was not performed until six weeks after Hamner was actually moved. That review generated a report with a “reason for initial assignment” section that was left empty. The subsequent “60-day review” was completely blank aside from Mr. Hamner’s identifying information.

Hamner was left alone for 23 to 24 hours a day. On the rare occasions he was allowed to leave his cell to shower or exercise, he had no contact with other prisoners. A routinely-broken light often left him in total darkness behind the solid-steel door of his single occupancy cell. Hamner suffered from hallucinations, panic attacks, insomnia, and depression. He frequently contemplated suicide.

Mr. Hamner filed suit, alleging that prison officials denied him his constitutional rights to due process and freedom from cruel and unusual punishment. However, the Eighth Circuit denied him relief on the basis of qualified immunity – even though the state hadn’t raised qualified immunity as a defense.