Notable Third Circuit ruling on process requirements for prisoner sex offender classification

The Third Circuit has a notable prisoner rights ruling today in Renchenski v. Williams, No. 07-3530 (3d Cir. Oct. 4, 2010) (available here), which gets started this way:

Plaintiff Charles Renchenski is serving a life sentence without the possibility for parole for murder in the first degree. Although he was never charged with, nor convicted of, a sexual offense, in 2005 Defendants classified Renchenski as a sex offender and recommended his enrollment in Pennsylvania’s Sex Offender Treatment Program (“SOTP”).  Renchenski filed this 42 U.S.C. § 1983 action alleging that his forced participation in sex offender treatment therapy violates several constitutional rights, including his: Fourteenth Amendment right to due process before being labeled a sex offender; Fifth Amendment right against self-incrimination; and Sixth Amendment right to have a jury adjudicate his guilt.  He also challenges the District Court’s conversion of Defendants’ motion to dismiss into a summary judgment motion without granting him leave to take discovery.  Because we hold that an inmate who has never been charged with, nor convicted of, a sex offense is entitled to due process before Pennsylvania classifies him as a sex offender, we reverse the District Court’s Order entering summary judgment as to his procedural due process claim.  We affirm the District Court in all other respects.