I. Statement of the Case
This matter is an appeal by Chris Coleman, #194028 (Coleman) of a final decision in a non-collateral or administrative matter issued by the South Carolina Department of Corrections
(DOC). Therefore, appellate review jurisdiction vests in the Administrative Law Court (ALC).
Slezak v. South Carolina Department of Corrections, 361 S.C. 327, 605 S.E.2d 506 (2004).
For inmate appeals, the nature of the appellate review depends upon the nature of the claim
presented. Appeals that do not implicate an inmate's state-created liberty or property interest
may be summarily decided. Id.("We hold that the [ALC] has jurisdiction over all properly
perfected inmate appeals, but clarify that it may summarily decide those appeals that do not
implicate an inmate's state-created liberty or property interest."). However, appeals that
implicate a protected interest are subject to the appellate review standards of the Administrative
Procedures Act (APA). Al-Shabazz v. State, 338 S.C. 354, 527 S.E.2d 742, 754 (2000) (The
ALC conducts an APA review "in an appellate capacity" and is "restricted to reviewing the
decision below.").
II. Analysis
Here, Coleman's claim asserts he was wrongly placed in security detention as punishment for
escaping from DOC in April 2003. Such a challenge implicates a liberty interest only if "the
State's action will inevitably affect the duration of [the inmate's] sentence" (Sandin v. Conner,
515 U.S. 472, 487 (1995)) or if the state has granted some benefit of which the inmate has been
deprived and the deprivation "imposes atypical and significant hardship on the inmate in relation
to the ordinary incidents of prison life." Sandin v. Conner, 515 U.S. 472, 484 (1995).
Here, DOC imposed a punishment of security detention. Such actions do not inevitably affect
the duration of the sentence imposed on Coleman. Further, the claim does not implicate a state-created liberty interest since DOC's action is not atypical and is not an action that is a significant
hardship in relation to the ordinary incidents of prison life. Rather, security detention is a
common practice in a prison setting..
Thus, the claim here fails to implicate a protected liberty or property interest and warrants a
summary dismissal to the challenge by Coleman of the security detention punishment.
III. Conclusion
The decision entered below by DOC against Chris Coleman, #194028 is AFFIRMED.
AND IT IS SO ORDERED.
____________________________
RAY N. STEVENS
Administrative Law Judge
Dated: January 13, 2005
Columbia, South Carolina
