DUSTIN ROBERT WILLIAMSON v. BRYAN STIRLING
US Court of Appeals for the Fourth Circuit, King, December 21, 2018,
Due Process – Immunity – A prosecutor was not “personally involved” in a detainee’s placement in solitary confinement where he merely delivered paperwork to defense counsel and prepared an order for confinement that was “never acted upon”
Facts:
In 2013, Williamson was being held in South Carolina pending a murder charge when he struck a guard and threatened violence against various law-enforcement officers as well as a local judge.
Williamson was placed in “safekeeper” status, which involved solitary confinement with nearly 24-hour cell confinement. Williamson was allowed recreation in an “outdoor cage” twice a week. Because of the intensity of this status, South Carolina law requires that it be reviewed and renewed every 90 days.
Williamson was kept in this status for approximately 1300 days while awaiting trial. Williamson had no reported infractions while in safekeeper status. He did, however, begin receiving treatment for various mental-health issues.
In 2017, Williamson was acquitted of the murder charge. He subsequently plead guilty to an armed robbery charge and was sentenced to time served plus five years of probation.
Williamson filed suit, claiming that he was denied due process by being improperly designated as a “safekeeper” and renewed in that status for years without cause.