Ryan T. Halligan v. James Oldham

United States Court of Appeals
For the Seventh Circuit
Chicago, Illinois 60604
Submitted May 1, 2025*
Decided May 5, 2025
Before
FRANK H. EASTERBROOK, Circuit Judge
MICHAEL B. BRENNAN, Circuit Judge
DORIS L. PRYOR, Circuit Judge
No. 24-1481
RYAN T. HALLIGAN,
Plaintiff-Appellant,
v.
JAMES OLDHAM, et al.,
Defendants-Appellees.
Appeal from the United States District
Court for the Southern District of
Indiana, Indianapolis Division.
No. 1:21-cv-01008-TWP-TAB
Tanya Walton Pratt,
Chief Judge.
O R D E R
Ryan Halligan filed this suit under 42 U.S.C. § 1983, alleging that, while he was a
pretrial detainee at the Bartholemew County Jail in Indiana, correctional officers
punished him by placing him in segregation without a hearing, in violation of his due
process rights. The district court entered summary judgment in favor of the defendants.
* We have agreed to decide the case without oral argument because the briefs and
record adequately present the facts and legal arguments, and oral argument would not
significantly aid the court. F ED. R. A PP . P. 34(a)(2)(C).
NONPRECEDENTIAL DISPOSITION
To be cited only in accordance with F ED. R. APP . P. 32.1

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No. 24-1481 Page 2
Because the undisputed evidence shows that the defendants placed Halligan in
segregation for administrative reasons and that they periodically reviewed his
placement, we affirm the judgment.
We review the district court’s summary-judgment order de novo, recounting the
facts and drawing inferences in the light most favorable to Halligan. See James v. Hale,
959 F.3d 307, 314 (7th Cir. 2020). On October 30, 2020, Halligan was arrested on charges
of attempted murder, aggravated battery, and strangulation, among other charges. The
charges attracted media attention because the alleged victim was a professional figure
skater who was well-known in the community. Halligan was booked in the
Bartholemew County Jail in Columbus, Indiana, and from the date of his arrest was
placed in a holding cell. Then, on November 16, jail administrators moved him to
administrative segregation.
Before his placement in segregation, Halligan requested several times to be
moved to a medical cell. The first request came on November 12, when he asked to be
moved for reasons including “mental problems,” his “high profile” case, and because
he wanted an hour out of his cell “for [his] mind to clear out.” He submitted similar
requests on November 15 and 16. In his final request, he stated that he wanted to be
moved to a medical cell so that he could go to the hospital a few times per week and
because he had a “high profile case” he did not “want to be around people.” Then, on
November 16, classification officers John Oldham and Devon Pattingill, along with jail
commander John Martoccia, determined that Halligan should be placed in
administrative segregation to protect him from the risk of retaliatory attacks by
detainees who had access to news about the case. (Halligan says that the jail officers
never told him why he was being moved to segregation.)
Classification officers reviewed housing assignments approximately every two
weeks by printing out a roster of the detainees in segregation and considering whether
each placement remained appropriate. Because Halligan’s placement in administrative
segregation stemmed from the notoriety of his charges, the periodic reviews of his
housing assignment did not yield any changes.
Soon after his placement in administrative segregation, Halligan began
requesting to be moved to the jail’s general population. In January 2021, he made
several requests, which coincided with a four-week lockdown to limit the spread of the
COVID-19 virus within the jail. Jail officials did not reassign him within this time. In
February, Halligan asked to be moved when the lockdown ended, but at that time he

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No. 24-1481 Page 3
was serving a 15-day disciplinary sentence, which ended on February 17. Halligan
again requested to be moved to general population on March 22. Three weeks later, on
April 13, an assistant jail commander approved Halligan’s request. It is unclear from the
record the precise reason for Halligan’s move to general population; nonetheless,
Halligan signed a form stating that he was “given the opportunity to stay in segregation
due to potentially having issues with inmates” and that he did not fear for his safety in
general population.
Halligan later filed this § 1983 suit against Oldham, Pattingill and Martoccia, the
jail officers who were involved in the decision to place him in administrative
segregation. He alleged that the defendants violated his due process rights by placing
him in segregation as punishment for his arrest in his high-profile case and that they
did not conduct meaningful periodic reviews to determine whether his placement in
segregation remained appropriate. Halligan also alleged that the defendants subjected
him to unconstitutional conditions of confinement by depriving him of recreational
time while he was in a holding cell.
The district court later granted the defendants’ motion for summary judgment.
The court determined that no reasonable jury could find that Halligan was placed in
segregation for purposes of punishment. Instead, the court explained, the undisputed
evidence showed that the defendants placed Halligan in segregation for administrative
reasons, namely, to protect him from the risk of physical attacks by detainees who had
access to news about the case. The court also determined that no reasonable jury could
conclude that Halligan was denied meaningful periodic review of his placement in
segregation. Lastly, the court ruled that the defendants did not subject Halligan to
unconstitutional conditions of confinement because 17 days without recreational time
(the number of days that Halligan spent in a holding cell) was not an objectively serious
threat to his health. (Halligan does not challenge the district court’s decision on his
conditions-of-confinement claim, and so we do not discuss it further.)
On appeal, Halligan first challenges the district court’s conclusion that the
defendants placed him in segregation for administrative purposes. As Halligan sees
things, he was placed in segregation as punishment for his case and should have
received a hearing beforehand. But we agree with the district court that the undisputed
evidence shows that the defendants placed Halligan in segregation not as a matter of
punishment, but instead to protect him from other detainees. To be sure, Halligan is
correct that a pretrial detainee may not be punished without due process. See Bell v.
Wolfish, 441 U.S. 520, 535–36 (1979). Yet no process is due when a detainee is placed in

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No. 24-1481 Page 4
segregation for nonpunitive reasons such as institutional safety or security. Higgs v.
Carver, 286 F.3d 437, 438 (7th Cir. 2002). Here, Halligan presented no evidence to
contradict the defendants’ affidavits averring that his segregation was nonpunitive—to
protect him from detainees who had access to news media covering his case.
Still, jail administrators must periodically review whether a detainee’s placement
in segregation remains appropriate. See Isby v. Brown, 856 F.3d 508, 524 (7th Cir. 2017)
(citing Hewitt v. Helms, 459 U.S. 460, 477 n.9 (1983)). Although the frequency of the
reviews is left to the discretion of jail administrators, see id. at 525, the reviews must be
“meaningful and non-pretextual,” id. at 527 (citation omitted). In other words, the
review must be “an actual review—i.e., one open to the possibility of a different
outcome.” Id. at 528. On this point, Halligan argues that the district court erred in
granting the defendants’ motion for summary judgment because the record is unclear
regarding whether they periodically reviewed his housing. We disagree.
The undisputed evidence shows that classification officers reviewed Halligan’s
placement every two weeks and that his housing assignment did not change because
his circumstances did not change: he remained at risk of physical attacks by detainees
who had access to news media covering his case. What is more, Halligan signed the
form acknowledging that he was “given the opportunity to stay in segregation due to
potentially having issues with inmates” and that he did not fear for his safety in the
general population of the jail. This is not a situation where the record presents
conflicting evidence as to the reasons for Halligan’s continued confinement. To the
contrary, the undisputed evidence shows that Halligan remained in segregation
because of the notoriety of his charges, and he was moved to general population only
after he assured jail officials that he did not fear for his safety. Cf. id. at 529 (summary
judgment improper where the record contained conflicting evidence as to the reasons
for the inmate’s continued segregation). On this record, a reasonable jury could not find
that Halligan was denied periodic reviews of his segregation or that his housing
assignment was punitive.
AFFIRMED

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