U.S. District Court: RESTRAINTS.

Williams v. Goord. 111 F.Supp.2d 280 (S.D.N.Y. 2000). A state prisoner brought a [sections] 1983 action against corrections officials alleging constitutional violations. The district court held that the conditions and duration of the prisoner's 75-day confinement in a Special Housing Unit (SHU) did not violate the prisoner's due process rights because they did not pose atypical or significant hardships. The conditions of the SHU included limited exercise times that were conducted in "cages" and limitations on the number of showers per week. The district court held that the fact that a prison employee issued a purportedly false misconduct report against the prisoner three days after he filed a grievance against the employee was insufficient to establish the prisoner's retaliation claim. But the district court denied summary judgment for the defendants on the issue of whether the officials knew that keeping the prisoner in mechanical restraints during his exercise period violated the Eighth Amendment. The court also held that there were genuine issues of material fact regarding whether placing the prisoner in mechanical restraints during his one-hour exercise period caused him "physical injury" as required by the Prison Litigation Reform Act (PLRA) to prevail on his Eighth Amendment claim. (Sullivan Correctional Facility, New York)