Following an attack on a prison official, New York inmate is sentenced to 14 years of solitary. After his term is up, he is kept in solitary on the grounds that he's a danger to the general prison population. He is held there for years, despite apparently good behavior. He challenges his continued detention in solitary as a violation of due process. After forty-six internal reviews, all reaching the same conclusion that he should remain in solitary confinement, he sued under 42 U.S.C. § 1983, arguing the process was a façade. District court: case dismissed. Second Circuit: Case undismissed. The cut-and-paste reviews of his continued detention were not meaningful process in light of his good behavior. Dissent: His behavior was probably good because you can't get in very much trouble when you're in solitary.
The case is Walker v. Bellnier, No. 21-650 (2d Cir. July 25, 2025).