Shirley, Mass. prison officials receive information that prisoner is a gang member threatening violence, so they place him in solitary confinement, where is held for a total of 611 days without being able to challenge or appeal the determination. A due process violation? First Circuit: Inmates do not have a right to avoid restrictive confinement conditions unless those conditions impose “atypical and significant hardship” compared to ordinary prison life. And because it’s not clearly established what kind of hardship meets that standard, qualified immunity all around.