In Smith v. Department. of Corrections,[1] the supreme court held that administrative hearings satisfied any due process requirements prior to ending prisoner employment. The Alaskan Department of Corrections placed two prisoners in administrative segregation after finding potential escape instruments allegedly belonging to the prisoners. The prisoners lost their jobs within the prison as a result of this administrative process. Though the following administrative hearing found that the escape instruments belonged to the prisoners, an appeal to the superior court overturned the decision but found that claims about lost wages without due process would require a separate claim. The prisoners brought a separate claim claiming that termination without a separate administrative proceeding violated their due process rights but the lower court granted summary judgment for the Department of Corrections. The supreme court affirmed the lower court’s ruling because there was not a constitutional interest in retaining the jobs so the administrative hearing was sufficient process. If the prison job served a rehabilitative function, it would have been protected by a higher standard for process, but the jobs were not rehabilitative. Further, the hearings for administrative segregation implemented a higher standard than those for rehabilitative program removals so due process was satisfied. Thus, the supreme court held that using the administrative segregation process to remove prisoners from their jobs did not violate the prisoners due process rights.
[1] 447 P.3d 769 (Alaska 2019).
