Coates v. Elzie

The court affirmed a trial court ruling that the Lorton Regulations Approval Act of 1982 does not give prisoners a right to sue for money damages resulting from unlawful segregation.

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Appeal from the Superior Court of the District of Columbia Hon. A. Franklin Burgess, Jr., Trial Judge

Argued January 23, 2001

Plaintiff-appellant Coates, then a sentenced prisoner housed in the general population at the Central Facility in Lorton, Virginia, was transferred to the Maximum Facility in October of 1997, where he remained in administrative segregation until April 1998. He later sought relief in Superior Court, contending that the placement in segregation violated his rights under the Lorton Regulations Approval Act of 1982 (LRAA or the Act) and the underlying regulations. The Superior Court agreed, and the District of Columbia has not challenged that decision. Instead, the sole issue before us is whether the trial court correctly ruled that the LRAA and the regulations do not create an implied cause of action for damages resulting from unlawful administrative segregation. We agree with the trial court that the LRAA reveals no intention of the legislature to provide such a right of action, and we therefore uphold the dismissal of Coates’s amended complaint for damages.

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Coates v. Elzie

The court affirmed a trial court ruling that the Lorton Regulations Approval Act of 1982 does not give prisoners a right to sue for money damages resulting from unlawful segregation.

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