9th Circuit upholds dismissal of prisoner's due process claim: a 15-day stint in segregation over…
Eiland v. Corecivic, Inc.
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9th Circuit upholds dismissal of prisoner's due process claim: a 15-day stint in segregation over a disciplinary matter does not rise to a protected liberty interest.
Why it matters
The Ninth Circuit affirmed the district court's summary judgment against Randy Carl Eiland, a prisoner who sued under federal civil rights law claiming his due process rights were violated during disciplinary proceedings related to an MP3 player containing child pornography images. The court found that the punishment Eiland received, 15 days in a segregation unit, did not implicate a protected liberty interest because it did not extend his sentence, cost him good-time credits, or impose an atypical and significant hardship compared to ordinary prison life. Because no protected liberty interest was at stake, his due process claim could not succeed.
Who it affects
This ruling directly affects prisoners in the Ninth Circuit who challenge disciplinary sanctions through civil rights lawsuits. It reinforces the existing legal standard that short-term segregation without loss of good-time credits or sentence extension generally will not support a due process claim.
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Decision issued Jul 20, 2026
Unpublished opinion
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Jul 20, 2026 · Unpublished opinion
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Randy Carl Eiland was a prisoner at Saguaro Correctional Center in Arizona who went through disciplinary proceedings after an MP3 player containing child pornography images was connected to him. He sued the warden and other facility officers under 42 U.S.C. Section 1983, arguing that those proceedings violated his constitutional right to due process. The federal district court in Arizona granted summary judgment for the defendants, and Eiland appealed to the Ninth Circuit. The central legal question was whether Eiland had a protected liberty interest that could trigger due process protections. Under the Supreme Court's decision in Sandin v. Conner, a prisoner's liberty interest is implicated only if a sanction extends the length of his sentence or imposes an atypical and significant hardship compared to ordinary prison life. The Ninth Circuit applies a three-part framework that looks at whether the conditions mirrored administrative segregation, the duration and degree of restraint, and whether the action affected the length of the prisoner's sentence. Applying that framework, the Ninth Circuit found that Eiland's 15-day placement in a segregation unit did not meet the Sandin standard. The court noted it had previously held that such a sanction is not atypical, that Eiland's sentence length was not affected, and that he did not lose any good-time credits. The court also observed that administrative segregation by itself does not ordinarily implicate a protected liberty interest. Additionally, the court found no allegation or record evidence that the disciplinary finding was based on no evidence at all, which would have been a separate potential ground for relief. The court unanimously affirmed the district court's ruling. There was no dissent. The decision was issued as an unpublished memorandum disposition, meaning it does not set binding precedent beyond the parties, except as allowed by Ninth Circuit Rule 36-3.
CITATION AND RECORD
Record source: CourtListener
NOT FOR PUBLICATION FILED UNITED STATES COURT OF APPEALS JUL 20 2026 MOLLY C. DWYER, CLERK U.S. COURT OF APPEALS FOR THE NINTH CIRCUIT RANDY CARL EILAND, No. 24-5153 D.C. No. Plaintiff - Appellant, 2:22-cv-01664-MTL v. MEMORANDUM* CORECIVIC, INC.; M FRINK; UNKNOWN PARTY, Jane Doe; S RODRIQUEZ, Warden for Saguaro Correction Center, Defendants - Appellees. Appeal from the United States District Court for the District of Arizona Michael T. Liburdi, District Judge, Presiding Submitted July 15, 2026** Before: BERZON, NGUYEN, and OWENS, Circuit Judges. Randy Carl Eiland appeals the summary judgment entered against him by the district court in his action under 42 U.S.C. § 1983 against the warden and other * This disposition is not appropriate for publication and is not precedent except as provided by Ninth Circuit Rule 36-3. ** The panel unanimously concludes this case is suitable for decision without oral argument. See Fed. R. App. P. 34(a)(2). officers of Saguaro Correctional Center. Eiland alleged due process violations arising from disciplinary proceedings concerning an MP3 player containing images of child pornography. The district court granted summary judgment for defendants, concluding that Eiland did not establish that he was deprived of a protected liberty interest. An inmate’s liberty interests are implicated when a sanction extends the length of his sentence or imposes an “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). We consider the following factors: “1) whether the challenged condition ‘mirrored th[e] conditions [of] administrative segregation and protective custody,’ and thus comported with the prison’s discretionary authority; 2) the duration of the condition, and the degree of restraint imposed; and 3) whether the state’s action will invariably affect the duration of the prisoner’s sentence.” Ramirez v. Galaza, 334 F.3d 850, 861 (9th Cir. 2003) (quoting Sandin, 515 U.S. at 486). 1. Eiland’s sanction did not implicate a protected liberty interest. He was placed in the segregation unit for 15 days. We have held that such a sanction does not meet the Sandin standard. Richardson v. Runnels, 594 F.3d 666, 672 (9th Cir. 2010). The sanction did not affect the length of his sentence. He did not lose good- time credits. “Typically, administrative segregation in and of itself does not 2 24-5153 implicate a protected liberty interest.” Serrano v. Francis, 345 F.3d 1071, 1078 (9th Cir. 2003). The sanction here was not “atypical.” Sandin, 515 U.S. at 484. 2. Eiland’s complaint did not allege, nor does the record suggest, that the sanction was based on no evidence. See Nonnette v. Small, 316 F.3d 872, 878 (9th Cir. 2002). AFFIRMED. 3 24-5153
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