South Carolina              
Administrative Law Court
Edgar A. Brown building 1205 Pendleton St., Suite 224 Columbia, SC 29201 Voice: (803) 734-0550

SC Administrative Law Court Decisions

William Adams, #124723 vs. SCDOC

South Carolina Department of Corrections

William Adams, #124723

South Carolina Department of Corrections



Grievance No. MCI 0250-03

I. Statement of the Case

This matter is an appeal by William Adams, #124723 (Adams) of a final decision in a non-collateral or administrative matter issued by the South Carolina Department of Corrections (DOC). Thus, 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).

However, 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."). On the other hand, appeals that implicate a protected interest are reviewed under 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, Adams presents a claim that amounts to a complaint challenging the conditions of confinement. Adams argues that the inmate phone system should be changed to reduce the costs of inmate telephone calls and to offer debit calling. 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, the claim does not inevitably affect the duration of the sentence imposed on Adams. 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, the telephone system and which company will be the facility's carrier are matters within the discretion of DOC officials. Such decisions will not be reversed unless arbitrary or capricious. Here Manning officials have reviewed the claim and determined that the telephone system is adequate for inmate use. Thus, the claim here fails to implicate a protected liberty or property interest and warrants a summary dismissal.

III. Conclusion

The decision entered below by DOC against William Adams, #124723 is AFFIRMED.




Administrative Law Judge

Dated: January 13, 2005

Columbia, South Carolina

Brown Bldg.






Copyright © 2024 South Carolina Administrative Law Court