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No Compensation for Inmates Kept Past Release Date: 8th Cir.

By Aditi Mukherji, JD on August 15, 2013 | Last updated on March 21, 2019

Iowa inmates aren't entitled to compensation for being held beyond their proper release, the Eighth Circuit Court of Appeals ruled last week. If the lawsuit had gone the other way, Iowa taxpayers may have had to dole out millions of dollars in settlements.

The inmates in the suit contended they were held too long under rules set forth by an Iowa Supreme Court decision in 2011.

But the Eighth Circuit affirmed the lower court ruling -- which held the inmates weren't entitled to compensation -- on the basis of qualified immunity.

Release Date Recalculation

In Anderson v. Iowa, the Hawkeye State's highest court made it clear that Iowa law requires that any defendant committed to the state Department of Corrections for supervision "who has probation revoked shall be given credit for such time served" (e.g., home supervision).

As a result of the ruling, nearly 3,500 inmates had recalculated release dates -- yet few were actually released on time.

The class-action lawsuit, filed against Iowa Department of Corrections director John Baldwin, claimed that "hundreds if not thousands of Iowa inmates" were kept past their release dates, which violated the Fourth, Eighth and 14th Amendments.

In addition to attorney fees, the suit sought compensatory damages "on a diem basis in an amount to be determined." To prevent future mistakes, the plaintiffs also sought the appointment of "a special master to supervise Department of Corrections to ensure that all inmates are released on or before their release dates."

Qualified Immunity

The issue was whether Baldwin "reasonably could have believed" the time he spent recalculating release dates was "lawful in light of clearly established law and the totality of the circumstances."

While the prisoners were undoubtedly kept longer than their release dates, the court held that Baldwin was protected by qualified immunity because he didn't have knowledge that what he was (or wasn't) doing violated the inmates' rights.

Baldwin apparently didn't have a court order or any substantial notice of the plaintiffs' over-detentions. Since Baldwin purportedly didn't know about the over-detentions, he didn't "recklessly disregard their constitutional right to release" and was therefore covered by qualified immunity.

Unfortunately, as a result of the ruling, "the court has made it more difficult for individuals to bring lawsuits for not being released after they have completed their sentences," one of the plaintiff's attorneys said of the ruling, reports The Des Moines Register.

Although the inmates lost the case, hopefully the Department of Corrections will consider this a close shave and remedy its protocol for handling releases, because something clearly needs to change.

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