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← 120 F.3d 500 - Beverati

Beverati’s Empirical Analysis

Citation profile

35
cited by 35 later decisions
2
states following
July 2025
most recently cited

4 district · 2 state decisions

How this case has been cited

Cited by 35 later decisions — most recently July 2025 · most notably 4 F. Supp. 2d 195 - McClary v. Kelly (1998), 213 W. Va. 503 - State Ex Rel. Appleby v. Recht (2002)

4 district · 2 state decisions

1701990200020102020decided

Later decisions citing this case, by decade. The current decade is in progress, and our corpus holds fewer opinions from the most recent years, so the latest bars are undercounted — not a real decline.

Relationships

Relies on Sandin v. Conner · Solem v. Helm · Hewitt v. Helms · Wilson v. Seiter · Rhodes v. Chapman

Most-quoted passages

The sentences later courts lift from this opinion, ranked by how many decisions quote each — the parts of the opinion doing the work. These counts are smaller than the citation total above because most of the 35 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.

  1. “complain[ed] of a six-month administrative confinement, claiming that the length of the confinement and the conditions to which they were exposed made the assignment an atypical and significant hardship.... [The] Inmates ... submitted affidavits attesting that the actual conditions in administrative segregation are more onerous than those specified in the prison regulations. They claim that when they were initially placed in segregation, their cells were infested with vermin; were smeared with human feces and urine; and were flooded with water from a leak in the toilet on the floor above. And, they assert, they were forced to use their clothing and shampoo to clean the cells. In addition, Inmates maintain that their cells were unbearably hot and that the food they received was cold. Furthermore, [Appellant] Van Aelst submitted an affidavit indicating that those assigned to administrative segregation did not receive clean clothing, linen, or bedding as often as required by the regulations governing administrative segregation; that they were permitted to leave their cells three to four times per week, rather than seven, and that no outside recreation was permitted; that there were no educational or religious services available; and that food was served in considerably smaller portions.”
    1 later decision quote this exact passage · from the majority
  2. “[s]tates may under certain circumstances create liberty interests which are protected by the Due Process Clause. But these interests will be generally limited to freedom from restraint which, while not exceeding the sentence in such an unexpected manner as to give rise to protection by the Due Process Clause of its own force, nonetheless imposes atypical and significant hardship on the inmate in relation to the ordinary incidents of prison life.”
    1 later decision quote this exact passage · from the majority
  3. “Prior to the decision of the Supreme Court in Sandin, the analysis of whether a prisoner was deprived of a liberty interest focused not on the nature of the deprivation experienced by the prisoner, but on the language of the applicable prison regulations and whether such language was 'mandatory'.” Beverati v. Smith, 120 F.3d 500 , 503 n. 3 (4th Cir.1997) (internal references omitted). This approach yielded”
    1 later decision quote this exact passage · from the majority

How this case has been treated — in progress

Whether each later court followed, distinguished, criticized, or overruled this decision. The treatment classification (task #35) runs highest-cited cases first and lights up here as it reaches this one.