Brown v. Oregon Department of Corrections

OPINION

GOODWIN, Circuit Judge:

Joshua Robert Brown, currently incarcerated at Oregon’s Snake River Correctional Institution (“SRCI”), appeals the district court’s summary judgment in his pro se 42 U.S.C. § 1983 action. Brown alleges that prison officials violated his due process rights by housing him in the Intensive Management Unit (“IMU”) without periodic, meaningful review of his status.

We hold that, under any plausible baseline, Brown’s conditions of confinement implicate a protected liberty interest giving rise to the procedural protections of the Due Process Clause. We also hold,…