Center on Sentencing and Corrections

LaChance v. Commissioner of Correction

LaChance v. Commissioner of Correction

LaChance v. Commissioner of Correction, 463 Mass. 767 (Massachusetts 2012)


The plaintiff in this case, Edmund LaChance, spent ten months in administrative segregation in a Special Management Unit on “awaiting action” status, as prison officials sought to transfer or reclassify him. Massachusetts’s Supreme Judicial Court found that “LaChance’s ten-month administrative segregation in the SMU on awaiting action status, during which he had the benefit of only informal status reviews, was unlawful. We conclude also, however, that the law in this regard was not clearly established at the time of the underlying events, and that, with respect to LaChance’s claim for damages, the defendants therefore are entitled to summary judgment, on the basis of qualified immunity.” In other words, the claims against the defendant prison officials “were barred by the doctrine of qualified immunity, where it would not have been clear to reasonable officials at the time when the alleged violations occurred that their behavior violated the plaintiff’s right to due process.”


Click here to read the decision of Massachusetts’s Supreme Judicial Court.


Keywords: due process, procedural due process, qualified immunity, reclassification hearing, prison classification, long-term segregation