Joseph Vidal, an incarcerated individual at Green Haven Correctional Facility, was sentenced to 270 days in the special housing unit (SHU) following a disciplinary hearing related to a March 2015 altercation with correctional officers. Vidal alleged he was denied basic procedural protections during his hearing, including the right to call witnesses and present documentary evidence in his defense.
The district court had granted summary judgment to New York Department of Corrections officials, concluding that Vidal's SHU confinement did not implicate a protected liberty interest under the Supreme Court's standard from Sandin v. Conner. The lower court therefore found that no due process protections were required.
The Second Circuit disagreed, finding that whether focusing on the 270 days imposed, the 180 days actually served, or other applicable periods of confinement, Vidal's disciplinary segregation 'constitutes an atypical and significant hardship based on duration alone.' The appeals court emphasized that such extended solitary confinement triggers constitutional due process protections.
During his SHU confinement, Vidal was restricted to one hour of recreation per day, two five-minute showers per week, limited law library access, and no telephone calls or packages. He also testified about harsh physical conditions, including extreme heat in cells lacking proper ventilation that became 'like an oven' during hot weather.
The case underscores ongoing debates about the constitutionality of prolonged solitary confinement in prisons. A New York state appellate court separately concluded in 2017 that the hearing officer had improperly denied Vidal's request to call witnesses, annulling the disciplinary determination, though Vidal had already completed his sentence by then.