Understanding Inmate Punishment and Due Process
Correctional officers often face difficult decisions when maintaining order and safety within their facilities. However, when it comes to disciplining pre-trial inmates, it’s critical to distinguish between necessary security actions and unconstitutional punishment.
The April 2025 Jail Pro lesson dives into this issue by analyzing the recent federal case Roundtree v. Dart, No. 23-2576 (7th Cir. Feb. 5, 2025). This case examines whether certain disciplinary actions imposed on an inmate crossed the line into unconstitutional punishment.
Case Summary: Roundtree v. Dart
In Roundtree v. Dart, Lonnial L. Roundtree Jr., a pretrial detainee at Cook County Jail, was transferred to a segregation unit on April 5, 2023, for an alleged rules violation. He awaited formal notification of the charges. Two days later, officers conducted a hearing at his cell door without prior notice or a copy of the disciplinary ticket. Roundtree requested to present witnesses and evidence but was denied. He remained in segregation without a clear explanation or duration. The Seventh Circuit Court found that pretrial detainees retain due process rights under the Fourteenth Amendment and vacated the district court’s dismissal of Roundtree’s procedural due process claim, remanding the case for further proceedings.
Key Legal Principle: Pre-Trial Inmates Cannot Be Punished Before Trial
Under the Due Process Clause of the Fourteenth Amendment, pre-trial inmates cannot be punished for their criminal charges prior to a formal finding of guilt. This means that any discipline imposed by jail staff must be for legitimate, non-punitive reasons—especially for those awaiting trial.
What This Means for Correctional Officers
Not all restrictions on an inmate’s freedom count as punishment. Officers can take preventative action for safety and security reasons—such as placing an inmate in administrative segregation—without providing prior notice. But when discipline is used in response to a rules violation, procedural safeguards are required to stay within constitutional bounds.
Officers must provide:
- Notice of the alleged rule violation
- An opportunity for the inmate to be heard (formally or informally)
- A written explanation of the outcome
- Periodic review of any administrative segregation
The Court’s Standard: Non-Punitive Purpose and Proportionality
When reviewing inmate discipline, courts ask two main questions:
- Is there a legitimate, non-punitive reason for the discipline?
- Is the disciplinary action excessive in relation to its stated purpose?
If the answer to either question is “no,” the action may be deemed unconstitutional.
Why It Matters
Understanding the difference between necessary security measures and unconstitutional punishment is essential for every jail staff member. A well-intentioned disciplinary decision that skips procedural steps or imposes overly harsh conditions could lead to legal exposure for the facility and its officers.
Jail Pro Helps Officers Navigate Legal Boundaries
This case and others like it are featured in Jail Pro’s monthly caselaw training—online, scenario-driven lessons designed specifically for correctional officers. With real federal cases, legal breakdowns, and actionable insights, Jail Pro helps your team:
- Stay compliant with constitutional standards
- Improve decision-making
- Reduce the risk of lawsuits
- Understand the legal consequences of daily actions
Ready to keep your team legally informed and professionally prepared?
Request a Demo today to see how Jail Pro can support your agency’s training needs.