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Civil rights Keyed to Jeffries, 5th Ed.
Preiser v. Rodriguez
Citation:
411 U.S. 475 (1973)Facts
The respondents were three New York state prisoners who had been deprived of good-conduct-time credits as a result of disciplinary proceedings. Rodriguez lost 120 days of good-time credits for alleged possession of contraband material in his cell. Katzoff lost 50 days for making derogatory comments about prison officials in his diary. Kritsky lost 590 days for allegedly being a leader in a prison protest demonstration. Each prisoner filed a combined civil rights action under § 1983 and petition for habeas corpus in federal district court, alleging that the prison officials had acted unconstitutionally in depriving them of good-time credits without due process. The District Court treated the actions as properly brought under § 1983, ruled that exhaustion of state remedies was not required, and ordered restoration of the good-time credits, which resulted in the immediate release of the prisoners. The Court of Appeals ultimately affirmed, relying on Wilwording v. Swenson, which held that prisoner complaints about conditions of confinement could be brought under § 1983 without exhausting state remedies.
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