Young v. Wall.

U.S. District Court

INMATE FUNDS

Young v. Wall, 359 F.Supp.2d 84 (D.R.I. 2005). A state prison inmate sued the director of a state corrections department, claiming that the practice of not crediting accrued interest to his inmate accounts funded through deduction from his wages violated his constitutional rights. The district court dismissed the case in part, and denied the director's motion to dismiss in part. The court held that a state statute that provided for wage deductions and the release of funds to the inmate upon his release did not create a property interest protected by the Takings Clause. The court found that the inmate was not entitled to interest under the rule that interest generally follows principal. But the court held that the inmate stated a procedural due process claim with regard to denial of interest in the face of an Inmate Account Policy that seemingly requires the equitable distribution of interest. The court noted that due to the rehabilitative nature of work assignments imposed on prisoners, payment for their labor is purely discretionary for the state, although it is possible for a state to create a right to be paid for labor which could create a limited protected interest in wages it chooses to pay prisoners. According to the court, the statute that provides deduction of 25% of the wages earned by the prison inmate, to be turned over to the inmate upon his release, did not confer upon the inmate full rights of possession, control and disposition of funds sufficient to support a [section] 1983 action. (Adult Correctional Institution, Rhode Island)