The following excerpt is from Dell'Orfano v. Romano, 962 F.2d 199 (2nd Cir. 1992):
In articulating his decision with regard to Dell'Orfano's administrative segregation claim, it appears that the district judge focused on whether the defendants had cause to confine Dell'Orfano in administrative segregation. However, the district court's analysis was incomplete because Dell'Orfano essentially complained that the defendants violated his right to federal due process by confining him to administrative segregation without written notice or a hearing. In light of Dell'Orfano's claim that he was denied due process, the more appropriate analysis would have been to examine whether Dell'Orfano's placement in administrative segregation deprived him of a protected liberty interest, and, if so, what process was due him. See Matiyn v. Henderson, 841 F.2d 31, 33-34 (2d Cir.), cert. denied, 487 U.S. 1220, 108 S.Ct. 2876, 101 L.Ed.2d 911 (1988).
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