The following excerpt is from Anderson v. Coughlin, 700 F.2d 37 (2nd Cir. 1983):
I believe this conclusory allegation is not adequate as a matter of law. Apart from the word "illegally" and references to the Constitution, the complaint simply states that appellant was placed in his cell "for no reason." There are no factual allegations that he was singled out for special punishment, was subjected to inhumane or specifically unreasonable treatment, or was the victim of defective procedures. Compare Haines v. Kerner, 404 U.S. 519, 92 S.Ct. 594, 30 L.Ed.2d 652 (1972) (pro se allegations of solitary confinement for disciplinary purposes in conditions which aggravated a pre-existing foot injury and circulatory ailment).
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