Double jeopardy; Multiple punishments for the same conduct; Administrative segregation as punishment; Civil vs criminal sanctions; Hudson v United States; Seling v Young; Michigan Department of Corrections (MDOC)

Holding that double jeopardy was not violated by defendant’s conviction despite his lengthy confinement in administrative segregation, the court affirmed. Defendant, an inmate, was charged with assault of a prison employee after he stabbed a corrections officer. He had already been sanctioned administratively with 20 days of disciplinary segregation and 60 days loss of privileges, after which the MDOC reclassified him to long-term administrative segregation based on security concerns. The trial court convicted him of assault. On remand, after factual findings that he remained in segregation for nearly four years, the court rejected his claim that this additional confinement constituted multiple punishments for the same conduct. The court explained that under Hudson, double jeopardy analysis requires courts to look to the statute or regulation “on its face” rather than the sanction actually imposed. As Seling emphasized, “harsh executive implementation cannot ‘transfor[m] what was clearly intended as a civil remedy into a criminal penalty.’” Because MDOC rules create civil, not criminal, sanctions, defendant’s administrative segregation did not bar later prosecution. The court noted that claims of excessive solitary confinement may raise concerns under other constitutional provisions, such as the Eighth Amendment, but “when it comes to addressing a Double Jeopardy Clause question, we must only consider the regulation on its face.”