Hatfield v. Scott.

U.S. Appeals Court

INMATE FUNDS

PRISONER ACCOUNTS

Hatfield v. Scott, 306 F.3d 223 (5th Cir. 2002). A state prison inmate brought a [section] 1983 action against a state's criminal justice department, alleging that failure to pay interest on his inmate trust fund account violated the Takings Clause. The district court denied summary judgment for the state and the state appealed. The appeals court reversed and remanded. The appeals court held that when interest from prisoners' trust accounts is used to pay for the administration of the fund, providing benefit to prisoners, there is no "taking." The court found that the inmate had waived any property interest he may have had in interest in the trust account, since participation in the statutorily-created trust fund was voluntary. The court noted that the inmate was fully informed that apportionment of interest was at the discretion of the state, and he could have elected to have his money deposited in an interest-bearing account as an alternative. (Texas Department of Criminal Justice, Inmate Trust Fund Department)