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Second Circuit – Prisoner disciplinary hearing: Vidal v. Venettozzi
Daily Record Staff//April 9, 2026//
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.
Case Digests
- Fourth Department – Circumstantial evidence charge: People v. Coleman
- Second Circuit – Sentencing conditions: United States v. McCrone
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- Fourth Department – Sex Offender Registration Act: People v. Wallace
- Second Circuit – Failure to accommodate religion: Bergin v. N.Y. Unified Court System
- Second Circuit – Sentencing: United States v. DeJesus
- Fourth Department – Ineffective assistance of counsel: People v. Castaneda
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- Fourth Department – Probable cause: People v. Asbury
- Fourth Department – Sex Offender Registration Act: People v. Berry
- Fourth Department – Grandparent custody: Barrett v. Gaines
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