Second Circuit - Prisoner disciplinary hearing: Vidal v. Venettozzi

Daily Record Staff//April 9, 2026//

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United States Court of Appeals for the Second Circuit

Prisoner disciplinary hearing — Liberty interest — Duration of confinement

24-2548-pr

Judges Robinson and Merriam

Background: The plaintiff appealed from the grant of summary judgment to the defendant on his Fourteenth Amendment procedural due process claim. Following a disciplinary hearing, he was sentenced to 270 days of confinement in the special housing unit. He argues he was denied the opportunity to call witnesses and present documentary evidence in his defense.

Ruling: The Second Circuit vacated and remanded. The court held that the plaintiff’s term of disciplinary segregation constituted an atypical and significant hardship based on duration alone which implicates a liberty interest that triggers due process protections.

Amit Jain, of MacArthur Justice Center, for the plaintiff-appellant; Andrea W. Trento, assistant solicitor general for the defendants-appellees.

Oral argument audio