Alaska Supreme Court

Wenona Diaz, Appellant v. State of Alaska, Department of Corrections; Jennifer Christensen; James Bowers; McHenry…

October 1, 20102010 Alas. LEXIS 109

Summary

The Alaska Supreme Court affirmed summary judgment against Diaz on her federal constitutional claims arising from an officer-escorted interrogation, her return to prison, brief segregation, and temporary telephone restrictions. The court held that Diaz was already in DOC custody, so the escort and interrogation did not implicate the Fourth Amendment; the conduct did not shock the conscience under substantive due process; and the confinement conditions created no protected liberty interest. Because no constitutional violation occurred, the private defendants could not be liable for conspiring with state actors under section 1983.