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September 12, 2026
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Inmate’s 47 Days in Isolation Sparked a Constitutional Lawsuit — But the 2nd Circuit Said the Law Wasn’t Clear Enough

December 19, 2025 1 min read

Joe Baltas claimed prison officials denied him religious freedom, basic hygiene, and due process while in solitary. A federal appeals court upheld the dismissal of his case on qualified immunity grounds.

Joe Baltas spent 47 days in a restricted housing unit at Garner Correctional Institution, locked down under “Chronic Discipline” status. He said it wasn…


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Free Exercise Prison & Institutional Religion

Holding: Federal appeals court upheld dismissal of inmate's religious freedom and due process claims on qualified immunity grounds where law was not clearly established.