Administrative segregation.

3. Administrative Segregation

U.S. District Court   Little v. Terhune, 200 F.Supp.2d 445 (D.N.J.
                      2002). A prisoner housed in a maximum security
  PROGRAMS            prison brought a civil rights suit against state
                      prison officials for allegedly violating his
  EQUAL PROTECTION    equal protection rights by failing to provide him
                      with educational programming while he was
                      confined in an administrative segregation unit.
                      The district court held that the denial of
                      educational programming to prisoners in
                      administrative segregation did not violate equal
                      protection on the basis that the programs were
                      available to the general prison population, to
                      younger inmates in administrative segregation, or
                      to all inmates in segregation units at other
                      institutions. The court noted that although
                      inmates do not have a constitutional right to
                      educational and work programs, once the state
                      grants such rights to prisoners it may not
                      invidiously discriminate against a class of
                      inmates in connection with those programs unless
                      the difference in treatment is rationally related
                      to the legitimate governmental interest to
                      justify the disparate treatment. The court found
                      a legitimate connection, where prison officials'
                      allocation priorities for the scarce resource of
                      educational services responded to security
                      concerns and budget restraints. The court also
                      found that there was a legitimate government
                      interest in promoting innovative prison programs
                      that might be stymied by a requirement that there
                      be system-wide uniformity. (New Jersey State
                      Prison)

U.S. Appeals Court    Rahman X v. Morgan, 300 F.3d 970 (8th Cir. 2002).
                      A state prisoner sued prison officials, alleging
  PLACEMENT           constitutional violations resulting from his
                      placement in segregation rather than death row.
  EQUAL PROTECTION    The district court dismissed the claim following
                      a bench trial. The appeals court affirmed,
  PRIVILEGES          finding that the prisoner was given process
                      sufficient to comply with the due process clause.
                      The appeals court held that there was a rational
                      basis for treating the prisoner differently from
                      other inmates who had been sentenced to death,
                      due to his prior violent assaults and attempts to
                      break out of his cell, which justified housing
                      him in a cell with more secure doors. The
                      prisoner had been sentenced to death for killing
                      a correctional officer and had spent 26 months in
                      segregation, where he was unable to watch
                      television, unlike prisoners housed on death row.
                      The court noted that while in segregation the
                      prisoner was not subjected to the same hardships
                      imposed on prisoners who were placed in
                      segregation for punitive reasons. (Arkansas
                      Department of Correction)