United States Third Circuit

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Steele v. Cicchi, 14-3127

In a Section 1983 suit brought by a pretrial detainee alleging that the defendant prison officials violated his due process rights when they transferred him to administrative segregation in the facility and restricted his phone privileges, which interfered with his ability to attempt to find a co-signer for his own bail, the district court's grant of summary judgment to defendants is affirmed where: 1) the limitation of plaintiff's phone privileges did not 'shock the conscience' and thus his substantive due process claim fails; 2) his placement in administrative segregation did not violate his substantive due process right to be free from punishment; and 3) there was non procedural due process violation because his transfer was for institutional security reasons rather than for discipline or punishment.

Appellate Information

  • Argued
  • Submitted
  • Decided
  • Published 2017/05/03




  • United States Third Circuit


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