October 4, 2010
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.
October 4, 2010 at 05:17 PM | Permalink
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